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| issue date = 05/10/2011
| issue date = 05/10/2011
| title = IR 05000416-11-002; on 01/21/2011 03/27/2011; Grand Gulf Nuclear Station, Integrated Resident and Regional Report; Fire Protection, Maintenance Effectiveness, Radiological Hazard Assessment and Exposure Controls, and Event Follow-Up
| title = IR 05000416-11-002; on 01/21/2011 03/27/2011; Grand Gulf Nuclear Station, Integrated Resident and Regional Report; Fire Protection, Maintenance Effectiveness, Radiological Hazard Assessment and Exposure Controls, and Event Follow-Up
| author name = Gaddy V G
| author name = Gaddy V
| author affiliation = NRC/RGN-IV/DRP/RPB-C
| author affiliation = NRC/RGN-IV/DRP/RPB-C
| addressee name = Perito M
| addressee name = Perito M
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| page count = 61
| page count = 61
}}
}}
See also: [[followed by::IR 05000416/2011002]]
See also: [[see also::IR 05000416/2011002]]


=Text=
=Text=
{{#Wiki_filter:       May 10, 2011 Mr. Mike Perito Vice President Operations Entergy Operations, Inc. Grand Gulf Nuclear Station  
{{#Wiki_filter:UNITED STATES
P.O. Box 756 Port Gibson, MS 39150   Subject: GRAND GULF NRC INTEGRATED INSPECTION REPORT NUMBER 05000416/2011002   Dear Mr. Perito:   On March 27, 2011, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Grand Gulf Nuclear Station. The enclosed integrated inspection report documents the inspection findings, which were discussed on April 14, 2011, with Mike Perito, Vice President Operations, and other members of your staff.   The inspections examined activities conducted under your license as they relate to safety and compliance with the Commission's rules and regulations and with the conditions of your license. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel.  
                                NUCLEAR REGULATORY COMMISSION
Based on the results of this inspection, the NRC has determined that one Severity Level IV violation of NRC requirements occurred. The NRC has also identified five issues that were evaluated under the risk significance determination process as having very low safety significance (Green). The NRC has determined that four of these findings have violations associated with these issues. Additionally, one licensee-identified violation, which was determined to be of very low safety significance, is listed in this report. However, because of their very low safety significance and because they were entered into your corrective action program, the NRC is treating these findings as noncited violations, consistent with Section 2.3.2 of the NRC Enforcement Policy.
                                                  REGI ON I V
If you contest the significance of the noncited violations, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, D.C. 20555-0001, with copies to the Regional Administrator, U.S. Nuclear Regulatory Commission, Region IV, 612 E. Lamar Blvd, Suite 400, Arlington, Texas, 76011-4125; the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, Washington, D.C. 20555-0001; and the NRC Resident Inspector at the facility. In addition, if you disagree with the cross-cutting aspect assigned to any finding in this report, you should provide a response within 30 days of the date UNITED STATESNUCLEAR REGULATORY COMMISSIONREGION IV612 EAST LAMAR BLVD, SUITE 400ARLINGTON, TEXAS 76011-4125 
                                        612 EAST LAMAR BLVD, SUITE 400
Entergy Operations, Inc. - 2 -  of this inspection report, with the basis for your disagreement, to the Regional Administrator, Region IV, and the NRC Resident Inspector at the facility. 
                                        ARLINGTON, TEXAS 76011-4125
In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, its enclosures, and your response, if you choose to provide one, will be made available electronically for public inspection in the NRC Public Document Room or from the NRC's document system (ADAMS), accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html.  To the extent possible, your response should not include any personal privacy or proprietary, information so that it can be made available to the Public without redaction.  Sincerely, /RA/ Vincent Gaddy, Chief Project Branch C Division of Reactor Projects  Docket:  50-416 License:  NPF-29  Enclosed: NRC Inspection Report 05000416/2011002 w/Attachment:  Supplemental Information  Distribution via ListServe   
                                                May 10, 2011
Entergy Operations, Inc. - 3 -  Electronic distribution by RIV: Regional Administrator (Elmo.Collins@nrc.gov) Deputy Regional Administrator (Art.Howell@nrc.gov) DRP Director (Kriss.Kennedy@nrc.gov) DRP Deputy Director (Troy.Pruett@nrc.gov) DRS Director (Anton.Vegel@nrc.gov) Senior Resident Inspector (Rich.Smith@nrc.gov) Branch Chief, DRP/C (Vincent.Gaddy@nrc.gov) Senior Project Engineer, DRP/C (Bob.Hagar@nrc.gov) Project Engineer, DRP/C (Rayomand.Kumana@nrc.gov) GG Administrative Assistant (Alley.Farrell@nrc.gov) Public Affairs Officer (Victor.Dricks@nrc.gov) Public Affairs Officer (Lara.Uselding@nrc.gov) Project Manager (Alan.Wang@nrc.gov) Branch Chief, DRS/TSB (Michael.Hay@nrc.gov) RITS Coordinator (Marisa.Herrera@nrc.gov) Regional Counsel (Karla.Fuller@nrc.gov) Congressional Affairs Officer (Jenny.Weil@nrc.gov) RIV OEDO/ETA (Stephanie Bush-Goddard@nrc.gov) OEMail Resource ROP Reports    File located:  R:\_REACTORS\_GG\GG 2011002 RP-RLS-vgg.docx SUNSI Rev Compl.  Yes  No ADAMS  Yes  No Reviewer Initials VGG Publicly Avail  Yes  No Sensitive  Yes  No Sens. Type Initials VGG SRI:DRP/PBC  SPE:DRP/PBC C:DRS/EB1 C:DRS/EB2 RLSmith  BHagar TRFarnholtz NFO'Keefe /RA/RCHagar for  /RA/ /RA/ /RA/ 5/4/2011  5/4/2011 4/21/2011 4/15/2011 C:DRS/OB C:TSS C:DRS/PSB1 C:DRS/PSB2 C:ACES/SAC MHaire MHay MPShannon GEWerner NTaylor /RA/ /RA/ /RA/ /RA/ /RA/ 4/15/2011 4/18/2011 4/18/2011 4/15/2011 4/18/2011 C:DRP/C    VGaddy    /RA/    5/10/11    OFFICIAL RECORD COPY  T=Telephone          E=E-mail        F=Fax 
Mr. Mike Perito
  - 1 - Enclosure U.S. NUCLEAR REGULATORY COMMISSION REGION IV Docket: 05000416 License: NPF-29 Report: 05000416/2011002 Licensee: Entergy Operations, Inc. Facility: Grand Gulf Nuclear Station Location: 7003 Baldhill Road Port Gibson, MS 39150 Dates: January 21, 2011, through March 27, 2011 Inspectors: R. Smith, Senior Resident Inspector M. Baquera, Resident Inspector, Palo Verde A. Fairbanks, Reactor Inspector C. Graves, Health Physicist L. Ricketson, P.E., Senior Health Physicist E. Uribe, Reactor Inspector Approved By: Vincent Gaddy, Chief, Project Branch C Division of Reactor Projects   
Vice President Operations
  - 2 - Enclosure SUMMARY OF FINDINGS  IR 05000416/2011002; 1/1/2011 - 3/27/2011; Grand Gulf Nuclear Station, Integrated Resident and Regional Report; Fire Protection, Maintenance Effectiveness, Radiological Hazard Assessment and Exposure Controls, and Event Follow-Up.  The report covered a 3-month period of inspection by resident inspectors and an announced baseline inspection by region-based inspectors.  Five Green noncited violations of significance were identified and one Green finding of significance was identified.  The significance of most findings is indicated by their color (Green, White, Yellow, or Red) using Inspection Manual Chapter 0609, "Significance Determination Process."  The cross-cutting aspect is determined using Inspection Manual Chapter 0310, "Components Within the Cross Cutting Areas."  Findings for which the significance determination process does not apply may be Green or be assigned a severity level after NRC management review.  The NRC's program for overseeing the safe
Entergy Operations, Inc.
operation of commercial nuclear power reactors is described in NUREG-1649, "Reactor Oversight Process," Revision 4, dated December 2006.  A. NRC-Identified Findings and Self-Revealing Findings   
Grand Gulf Nuclear Station
Cornerstone:  Mitigating Systems  SLIV.  Inspectors identified a noncited violation of 10 CFR 50.71(e)(4), which requires the final safety analysis report be updated, at intervals not exceeding 24
P.O. Box 756
months, to reflect changes made in the facility or procedures described in the final safety analysis report.  Licensee personnel failed to update the original revision of the final safety analysis report to reflect the actual number of low pressure coolant injection loops available for automatic initiation during shutdown cooling operations in Mode 3.  The licensee plans to update the final safety analysis report at the next scheduled revision.  This finding was entered into the licensee's corrective action program as condition report CR-GGN-2011-01631. The failure of licensing personnel to update the final safety analysis report to reflect the available low pressure coolant injection loops for automatic initiation during shutdown cooling operations in Mode 3 was a performance deficiency.  This finding was evaluated using traditional enforcement because it had the potential for impacting the NRC's ability to perform its regulatory function.  The inspectors used the NRC Enforcement Policy, dated September 30, 2010, to evaluate the significance of this violation.  Consistent with the NRC Enforcement
Port Gibson, MS 39150
Policy, this finding was determined to be a Severity Level IV noncited violation.    Green.  The inspectors identified a noncited violation of 10 CFR Part 50.65(a)(2) for the licensee's failure to demonstrate that the performance of the train B control room air conditioner was being effectively controlled through the performance of appropriate preventive maintenance.  Engineering did not properly evaluate maintenance rule functional failures resulting in the system remaining in an a(2) status instead of an a(1) status.  As corrective action, the 
Subject: GRAND GULF NRC INTEGRATED INSPECTION REPORT NUMBER
  - 3 - Enclosure train B control room air conditioner was moved into an a(1) status.  The licensee entered this issue into their corrective action program as Condition Report  CR-GGN-2011-01623.    The finding was more than minor because it was associated with the equipment performance attribute of the Mitigating Systems Cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences.  Inspectors performed a Phase 1 screening, in accordance with Inspection Manual Chapter 0609, Attachment 4, "Phase 1 - Initial Screening and Characterization of Findings," and determined that the finding was of very low safety significance (Green) because the maintenance rule aspect of the finding did not cause an actual loss of safety function of the system nor did it cause a component to be inoperable.  As corrective action, the train B control room air conditioner was moved into an (a)(1) status.  This finding had a crosscutting aspect in the area of human performance associated with the decision making component because licensee personnel failed to make appropriate safety-significant or risk-significant decisions to address the multiple failures of the train B control room air conditioner compressor. [H.1(a)] (Section 1R12.b.2)  Green.  The inspectors reviewed a self-revealing noncited violation of 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, after the licensee failed to determine the cause and prevent recurrence of a significant condition adverse to quality associated with the train B control room air conditioner compressor tripping due to low oil pressure.  Specifically, on December 13, 2010, the train B control room air conditioner compressor tripped on low oil pressure after the licensee had performed a root cause analysis to identify the cause and prevent recurrence of a similar compressor trip on October 14, 2010.  As immediate corrective action, the licensee installed an inline suction filter.  No additional failures have occurred since its installation.  The finding was entered into the licensee's corrective action program as Condition Report CR-GGN-2010-07315. This finding was more than minor because it was associated with the equipment performance attribute of the Mitigating Systems Cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences.  Using Inspection Manual Chapter 0609, "Significance Determination Process," Phase 1 worksheets, the inspectors determined that a Phase 2 analysis was required because the finding represented a loss of system safety function.  The plant-specific risk informed notebook does not include the evaluation of risk caused by the loss of cooling to the main control room. 
          05000416/2011002
Therefore, the senior reactor analyst conducted a Phase 3 analysis.  Based on the bounding analysis, the analyst determined that the change in core damage frequency result was 5.9 x 10-7.  This noncited violation was therefore determined to be of very low safety significance (Green).  This finding had a crosscutting aspect in the area of problem identification and resolution associated with the corrective action program component because licensee personnel failed to 
Dear Mr. Perito:
  - 4 - Enclosure thoroughly evaluate the multiple failures of the train B control room air conditioner compressor. [P.1(c)] (Section 4OA3.1.b)  Cornerstone:  Barrier Integrity  Green . The inspectors identified a noncited violation of Facility Operating License Condition 2.C(41), involving the failure to ensure that transient combustible were not stored in the fire exclusion zone near the independent spent fuel storage installation.  The inspectors performed a quarterly fire protection inspection of independent spent fuel storage installation and identified a large air conditioner with combustible material covering it located in the fire exclusion zone that was
On March 27, 2011, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection
within 60 feet of the dry fuel storage pad.  The inspectors determined through interviews that the material had been placed there the previous day by the maintenance department.  As immediate corrective action the licensee removed the combustible material from the area.  The finding was entered into the licensee's corrective action program as Condition Report CR-GGN-2011-00455. This finding was more than minor because it was associated human performance attribute of the Barrier Integrity Cornerstone to provide reasonable assurance that physical design barriers protect the public from radionuclide releases caused
at your Grand Gulf Nuclear Station. The enclosed integrated inspection report documents the
by accidents or events.  Using Manual Chapter 0609, Appendix F, "Fire Protection Significance Determination Process," the inspectors determined that the finding impacted the fire prevention and administrative controls category.  The inspectors assigned a low degradation rating due to the fact that the amount of combustible material in the area was minimal.  The inspectors concluded that the finding was of very low safety significance (Green) due to the fact there were
inspection findings, which were discussed on April 14, 2011, with Mike Perito, Vice President
no fire ignition sources in the area.  The cause of this finding has a crosscutting aspect in the area of human performance associated with the work practices component because the licensee failed to effectively communicate expectations regarding storage of combustible material near the dry fuel storage pad. [H.4(b)]  (Section 1R05.1.b)  Green. The inspectors reviewed a self-revealing, Green finding of EN-DC-115, "Engineering Change Process," involving the failure to maintain adequate design control measures associated with the installation of the mitigation monitoring system.  On November 8, 2010, a reactor coolant pressure boundary failure occurred at the skid mounted Online Noble Chemical - Mitigation Monitoring System pump inside primary containment.  The positive displacement sample pump ejected the pump piston from the housing, resulting in an approximate  7 gpm leak of reactor coolant.  The steam leak resulted in a reactor recirculation system flow control valve lockup (due to hydraulic power unit motor failure) and approximately 15,000 square feet of contaminated area in the primary containment structure.  The licensee failed to ensure proper validation testing for the pump prior to installation.  Specifically, the licensee did not ensure that the pump could withstand the operating pressures and temperatures of the system in 
Operations, and other members of your staff.
  - 5 - Enclosure which it was installed.  The licensee removed the mitigation monitoring system from service and isolated the skid from the reactor water cleanup system.  This finding was entered into the licensee's corrective action program as Condition Report CR-GGN-2010-07852. The finding is more than minor because it affects the design control attribute of the Barrier Integrity Cornerstone to provide reasonable assurance that physical design barriers protect the public from radionuclide releases caused by accidents or events.  Therefore, using inspection Manual Chapter 0609, "Significance Determination Process," Phase 1 Worksheet for LOCA initiators, the inspectors concluded that the finding was of very low safety significance (Green) because the failure of the mitigation monitoring system would not have exceeded technical specifications limits for identified leakage in the reactor coolant system.  This finding has a crosscutting aspect in the work practices component of the human
The inspections examined activities conducted under your license as they relate to safety and
performance area; because the licensee failed to adequately oversee the design of the mitigation monitoring system such that nuclear safety is supported. [H.4(c)] (Section 4OA3.2.b)  Cornerstone:  Occupational Radiation Safety  Green.  The inspectors identified a noncited violation of Technical Specification 5.7.2, resulting from the licensee's failure to use a qualified radiation protection technician to provide direct continuous coverage of work in a locked high radiation area.  The finding was placed into the corrective action program as Condition Report CR-GGN-2011-01045, and corrective action was being evaluated.  The failure to use a qualified radiation protection technician to provide direct continuous coverage of work in a locked high radiation area is a performance deficiency.  The finding was more than minor because it was associated with the Occupational Radiation Safety Cornerstone attribute (exposure control) of program and process and affected the cornerstone objective, in that, the failure to use qualified radiation protection technicians to provide job coverage in a high radiation area with dose rates in excess of 1000 mrem/hr had the potential to
compliance with the Commissions rules and regulations and with the conditions of your license.
increase personnel dose.  Using the Occupational Radiation Safety Significance Determination Process, the inspectors determined the finding to have very low safety significance because: (1) it was not associated with ALARA planning or work controls, (2) there was no overexposure, (3) there was no substantial potential for an overexposure, and (4) the ability to assess dose was not compromised.  (Section 2RS01.b)  B. Licensee-Identified Violations  Violations of very low safety significance, which were identified by the licensee, have been reviewed by the inspectors.  Corrective actions taken or planned by the licensee have been entered into the licensee's corrective action program.  These violations and corrective action tracking numbers (condition report numbers) are listed in Section 4OA7. 
The inspectors reviewed selected procedures and records, observed activities, and interviewed
  - 6 - Enclosure REPORT DETAILS  Summary of Plant Status  Grand Gulf Nuclear Station began the inspection period at full rated thermal power.  On January 9, 2011, operators reduced power to 68 percent for a planned control rod sequence exchange and isolation of the moisture separator reheaters (MSRs) second stage steam to both the 'A' and 'B' MSRs due to tube leaks in the 'A' MSR.  The plant was returned to 96 percent power on January 10, 2011, which was maximum power level allowed with MSR second stage steam isolated.  On February 18, 2011, operators reduced power to 77 percent for monthly control rod testing, turbine testing, and to remove 'B' heater drain pump from service in an attempt to repair a steam leak on the heater drain pump 'B' discharge flange.  The plant was returned to 96 percent power on February 19, 2011.  On March 11, 2011, operators reduced power to 84 percent power for a planned control rod testing and to remove 'B' heater drain pump from service in another attempt to repair a steam leak on the heater drain pump 'B' discharge flange.  The plant was returned to 96 percent power on March 12, 2011.  On March 23, 2011, operators reduced power to 93 percent power to remove the 'B' heater drain pump from service again in
personnel.
another attempt to repair a steam leak on the heater drain pump 'B' pump discharge flange.  The plant was returned to 96 percent power on March 12, 2011.  The plant remained at 96 percent power for the remainder of the inspection period.  1. REACTOR SAFETY  Cornerstones:  Initiating Events, Mitigating Systems, Barrier Integrity, and Emergency Preparedness  1R01 Adverse Weather Protection (71111.01) .1 Readiness for Seasonal Extreme Weather Conditions a. The inspectors performed a review of the adverse weather procedures for seasonal extreme low temperatures.  The inspectors verified that weather-related equipment deficiencies identified during the previous year were corrected prior to the onset of
Based on the results of this inspection, the NRC has determined that one Severity Level IV
seasonal extremes, and evaluated the implementation of the adverse weather preparation procedures and compensatory measures for the affected conditions before the onset of, and during, the adverse weather conditions. Inspection Scope  During the inspection, the inspectors focused on plant-specific design features and the procedures used by plant personnel to mitigate or respond to adverse weather conditions.  Additionally, the inspectors reviewed the updated final safety analysis report and performance requirements for systems selected for inspection and verified that operator actions were appropriate as specified by plant-specific procedures.  Specific documents reviewed during this inspection are listed in the attachment.  The inspectors
violation of NRC requirements occurred. The NRC has also identified five issues that were
also reviewed corrective action program items to verify that plant personnel were identifying adverse weather issues at an appropriate threshold and entering them into 
evaluated under the risk significance determination process as having very low safety
  - 7 - Enclosure their corrective action program in accordance with station corrective action procedures.  The inspectors' reviews focused specifically on the following plant systems:  Standby service water  Emergency diesel generators  Plant service water  Fire water pumps and tanks  These activities constitute completion of one readiness for seasonal adverse weather sample as defined in Inspection Procedure 71111.01-05.  b. No findings were identified. Findings  .2 Readiness for Impending Adverse Weather Conditions a. Since extreme cold conditions and icing were forecast in the vicinity of the facility for January 9, 2011, the inspectors reviewed overall preparations/protection for the expected weather conditions.  On January 7, 2011, the inspectors inspected the standby service water towers because their safety-related functions could be affected as a result of the extreme cold and icing conditions forecast for the facility.  The inspectors observed space heater operation and weatherized enclosures to ensure operability of affected systems.  The inspectors reviewed licensee procedures and discussed potential compensatory measures with control room personnel.  The inspectors focused on plant management's actions for implementing the station's procedures for ensuring adequate personnel for safe plant operation and emergency response would be available.  Specific documents reviewed during this inspection are listed in the attachment. Inspection Scope  These activities constitute completion of one readiness for impending adverse weather condition sample as defined in Inspection Procedure 71111.01-05.  b. No findings were identified. Findings  1R04 Equipment Alignments (71111.04) .1 Partial Walkdown a. The inspectors performed partial system walkdowns of the following risk-significant systems: Inspection Scope  Division II standby service water system during Division I maintenance outage 
significance (Green). The NRC has determined that four of these findings have violations
  - 8 - Enclosure  Residual heat removal system B during residual heat removal system A maintenance outage  Residual heat removal system C during residual heat removal system A maintenance outage  Division II standby diesel generator system during Division I maintenance outage  Standby liquid control system A during standby liquid control system B maintenance outage  The inspectors selected these systems based on their risk significance relative to the reactor safety cornerstones at the time they were inspected.  The inspectors attempted to identify any discrepancies that could affect the function of the system, and, therefore, potentially increase risk.  The inspectors reviewed applicable operating procedures, system diagrams, UFSAR, technical specification requirements, administrative technical specifications, outstanding work orders, condition reports, and the impact of ongoing work activities on redundant trains of equipment in order to identify conditions that could have rendered the systems incapable of performing their intended functions.  The inspectors also inspected accessible portions of the systems to verify system components and support equipment were aligned correctly and operable.  The
associated with these issues. Additionally, one licensee-identified violation, which was
inspectors examined the material condition of the components and observed operating parameters of equipment to verify that there were no obvious deficiencies.  The inspectors also verified that the licensee had properly identified and resolved equipment alignment problems that could cause initiating events or impact the capability of mitigating systems or barriers and entered them into the corrective action program with the appropriate significance characterization.  Specific documents reviewed during this inspection are listed in the attachment. 
determined to be of very low safety significance, is listed in this report. However, because of
These activities constitute completion of five partial system walkdown samples as defined in Inspection Procedure 71111.04-05.  b. No findings were identified. Findings  1R05 Fire Protection (71111.05)  Quarterly Fire Inspection Tours a. The inspectors conducted fire protection walkdowns that were focused on availability, accessibility, and the condition of firefighting equipment in the following risk-significant plant areas: Inspection Scope  Division II diesel generator room (1D303) 
their very low safety significance and because they were entered into your corrective action
  - 9 - Enclosure  Residual heat removal pump and heat exchanger rooms A (1A102 and 1A103)  Residual heat removal pump and heat exchanger rooms B (1A105 and 1A106)  Reactor Core Isolation Pump Room (1A104)  Dry fuel storage pad area (Area 59 the Yard)  The inspectors reviewed areas to assess if licensee personnel had implemented a fire protection program that adequately controlled combustibles and ignition sources within the plant; effectively maintained fire detection and suppression capability; maintained passive fire protection features in good material condition; and had implemented adequate compensatory measures for out of service, degraded or inoperable fire protection equipment, systems, or features, in accordance with the licensee's fire plan.  The inspectors selected fire areas based on their overall contribution to internal fire risk as documented in the plant's Individual Plant Examination of External Events with later additional insights, their potential to affect equipment that could initiate or mitigate a plant transient, or their impact on the plant's ability to respond to a security event.  Using the documents listed in the attachment, the inspectors verified that fire hoses and extinguishers were in their designated locations and available for immediate use; that
program, the NRC is treating these findings as noncited violations, consistent with Section 2.3.2
fire detectors and sprinklers were unobstructed; that transient material loading was within the analyzed limits; and fire doors, dampers, and penetration seals appeared to be in satisfactory condition.  The inspectors also verified that minor issues identified during the inspection were entered into the licensee's corrective action program.  Specific documents reviewed during this inspection are listed in the attachment. 
of the NRC Enforcement Policy.
These activities constitute completion of five quarterly fire-protection inspection samples as defined in Inspection Procedure 71111.05-05.  b. Findings Introduction .  The inspectors identified a Green noncited violation of Facility Operating License Condition 2.C(41), involving the failure to ensure that transient combustible were not stored in the fire exclusion zone near the independent spent fuel storage installation. Description .  On January 24, 2011, the inspectors performed a quarterly fire protection inspection of independent spent fuel storage installation.  The inspectors identified a large air conditioner with combustible material covering it located in the fire exclusion zone that appeared to be within 60 feet of the dry fuel storage pad.  The inspectors brought this to the attention of the work center senior reactor operator.  The work center senior reactor operator contacted the site fire engineer, who walked down the fire exclusion zone and determined that the combustible material covering the air conditioner was within the 60 feet of the dry fuel storage pad, which is in violation of plant procedural requirements.  The inspectors determined through interviews that the material had been placed there the day before by the maintenance department.  The site had the air conditioner and the covering material removed from the fire exclusion zone to restore
If you contest the significance of the noncited violations, you should provide a response within
compliance.  The licensee documented this violation in Condition Report CR-GGN-2011-00455.  Its short-term corrective actions included removing the combustible material from the area. 
30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear
  - 10 - Enclosure Analysis.  The inspectors determined that the failure to follow fire protection procedures developed for control of transient combustible material stored near the dry spent fuel storage pad was a performance deficiency.  This finding was more than minor because it was associated human performance attribute of the Barrier Integrity Cornerstone to provide reasonable assurance that physical design barriers protect the public from radionuclide releases caused by accidents or events.  Using Manual Chapter 0609, Appendix F, "Fire Protection Significance Determination Process," the inspectors determined that the finding impacted the fire prevention and administrative controls category.  The inspectors assigned a low degradation rating due to the fact that the amount of combustible material in the area was minimal.  The inspectors concluded that the finding was of very low safety significance (Green) due to the fact there were no fire ignition sources in the area.  The finding has a crosscutting aspect in the area of human performance associated with the work practices component because the licensee failed to effectively communicate expectations regarding storage of combustible material near the dry fuel storage pad. [H.4(b)]  Enforcement.  Grand Gulf Nuclear Station Facility Operating License Condition 2.C(41) states, in part, that the plant "shall implement and maintain in effect all provisions of the Fire Protection Program as described in the UFSAR."  UFSAR Section 9B, "Administrative Controls," section 9B.6.a, governs the handling and limits the use of ordinary combustible materials in safety related areas.  Fire area 59, defined as the yard, contains the fire exclusion area next to the dry fuel storage pad and prohibits the storage
Regulatory Commission, ATTN: Document Control Desk, Washington, D.C. 20555-0001, with
of any combustible material in this area.  Contrary to this, on January 23, 2011, the licensee stored combustible material inside the transient combustible exclusion zone near the dry fuel storage pad.  The licensee restored compliance by removing the
copies to the Regional Administrator, U.S. Nuclear Regulatory Commission, Region IV,
material from the area on January 25, 2011.  Because the finding was of very low safety significance (Green) and was documented in the licensee's corrective action program as CR-GGN-2011-0455, this finding is being treated as a noncited violation (NCV) consistent with Section VI.A of the NRC Enforcement Policy:  NCV 05000416/2011002-01; Transient Combustible Stored in the Fire Exclusion Zone Near the Independent Spent Fuel Storage Installation.  1R06 Flood Protection Measures (71111.06) a. The inspectors reviewed the flooding analysis, and plant procedures to assess seasonal susceptibilities involving internal flooding; reviewed the Updated Final Safety Analysis Report and corrective action program to determine if licensee personnel identified and corrected flooding problems; inspected underground bunkers/manholes to verify the adequacy of sump pumps, level alarm circuits, cable splices subject to submergence, and drainage for bunkers/manholes; subject to flooding that contain cables whose failure
612 E. Lamar Blvd, Suite 400, Arlington, Texas, 76011-4125; the Director, Office of
could disable risk-significant equipment.  The inspectors walked down the areas listed below.  Specific documents reviewed during this inspection are listed in the attachment.  Inspection Scope  January 11, 2011, division 1 and 2 standby service water manholes 
Enforcement, U.S. Nuclear Regulatory Commission, Washington, D.C. 20555-0001; and the
  - 11 - Enclosure These activities constitute completion of one bunker/manhole sample as defined in Inspection Procedure 71111.06-05.  b. No findings were identified. Findings 
NRC Resident Inspector at the facility. In addition, if you disagree with the cross-cutting aspect
1R07 Heat Sink Performance (71111.07) a. The inspectors reviewed licensee programs, verified performance against industry standards, and reviewed critical operating parameters and maintenance records for the Division 1 emergency diesel generator jacket water and lube oil heat exchangers.  The inspectors verified that performance tests were satisfactorily conducted for heat exchangers/heat sinks and reviewed for problems or errors; the licensee utilized the periodic maintenance method outlined in EPRI Report NP 7552, "Heat Exchanger Performance Monitoring Guidelines"; the licensee properly utilized biofouling controls; the licensee's heat exchanger inspections adequately assessed the state of cleanliness of their tubes; and the heat exchanger was correctly categorized under 10 CFR 50.65, "Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants."  Specific documents reviewed during this inspection are listed in the attachment. Inspection Scope  These activities constitute completion of one heat sink inspection sample as defined in Inspection Procedure 71111.07-05.  b.  Findings No findings were identified. 
assigned to any finding in this report, you should provide a response within 30 days of the date
1R11 Licensed Operator Requalification Program (71111.11) a. On January 31, 2011, the inspectors observed a crew of licensed operators in the plant's simulator to verify that operator performance was adequate, evaluators were identifying and documenting crew performance problems and training was being conducted in accordance with licensee procedures.  The inspectors evaluated the following areas:  Inspection Scope  Licensed operator performance  Crew's clarity and formality of communications  Crew's ability to take timely actions in the conservative direction  Crew's prioritization, interpretation, and verification of annunciator alarms 
Crew's correct use and implementation of abnormal and emergency procedures 
  - 12 - Enclosure  Control board manipulations 
Oversight and direction from supervisors 
Crew's ability to identify and implement appropriate technical specification actions and emergency plan actions and notifications 
The inspectors compared the crew's performance in these areas to preestablished operator action expectations and successful critical task completion requirements.  Specific documents reviewed during this inspection are listed in the attachment.  These activities constitute completion of one quarterly licensed-operator requalification program sample as defined in Inspection Procedure 71111.11.  b. No findings were identified. Findings  1R12 Maintenance Effectiveness (71111.12) a. The inspectors evaluated degraded performance issues involving the following risk significant systems: Inspection Scope  Appendix R emergency lighting units (Z92)  Control room air conditioning (Z51)  Residual heat removal (E12)  The inspectors reviewed events such as where ineffective equipment maintenance has resulted in valid or invalid automatic actuations of engineered safeguards systems and independently verified the licensee's actions to address system performance or condition problems in terms of the following:  Implementing appropriate work practices  Identifying and addressing common cause failures  Scoping of systems in accordance with 10 CFR 50.65(b) 
Characterizing system reliability issues for performance 
Charging unavailability for performance  Trending key parameters for condition monitoring 
  - 13 - Enclosure  Ensuring proper classification in accordance with 10 CFR 50.65(a)(1) or -(a)(2)  Verifying appropriate performance criteria for structures, systems, and components classified as having an adequate demonstration of performance through preventive maintenance, as described in 10 CFR 50.65(a)(2), or as requiring the establishment of appropriate and adequate goals and corrective actions for systems classified as not having adequate performance, as described in 10 CFR 50.65(a)(1) 
The inspectors assessed performance issues with respect to the reliability, availability, and condition monitoring of the system.  In addition, the inspectors verified maintenance effectiveness issues were entered into the corrective action program with the appropriate significance characterization.  Specific documents reviewed during this inspection are listed in the attachment.  These activities constitute completion of three quarterly maintenance effectiveness samples as defined in Inspection Procedure 71111.12-05.  b. .1 Failure to Update Available Low Pressure Cooling Injection Loops in the Updated Final Safety Analysis Report Findings Introduction.  Inspectors identified a Severity Level IV, noncited violation for the licensee's failure to update the final (updated) safety analysis report in accordance with 10 CFR 50.71(e)(4).  Specifically, the licensee failed to update Section 6.3, "Emergency Core Cooling Systems," to appropriately reflect the available emergency core cooling equipment during shutdown cooling operations in Mode 3. Description.  On February 28, 2011, while reviewing the updated final safety analysis report for a maintenance effectiveness inspection of the residual heat removal system,
the inspectors determined that Section 6.3.1.1.1.e, "Emergency Core Cooling Systems," states, "The ECCS is designed to satisfy all criteria specified in Section 6.3 for any normal mode of reactor operation."  Additionally, Section 6.3.1.1.2.d states, "In the event of a break in a pipe that is part of the reactor coolant pressure boundary, no single active component failure in the emergency core cooling system shall prevent automatic initiation and successful operation of less than the following combination of emergency core cooling system equipment: 1) Three low pressure coolant injection loops, the low pressure core spray and the automatic depressurization system (i.e., high pressure core spray failure); 2) Two low pressure coolant injection loops, the high pressure core spray and the automatic depressurization system (i.e., low pressure core spray diesel generator failure); and 3) One low pressure coolant injection loop, the low pressure core spray, the high pressure core spray and automatic depressurization system (i.e., low pressure coolant injection diesel generator failure)." Procedure 03-1-01-3, "Plant Shutdown," Revision 118, Section 6.14 states, "When shutdown cooling is placed in service at less than 135 psig, then the associated containment spray and low pressure coolant injection systems may be considered 
  - 14 - Enclosure operable if capable of being manually realigned and not otherwise inoperable."  Inspectors noted that because the residual heat removal system that provides shutdown cooling in Mode 3 is not available for automatic initiation (must be manually realigned) of low pressure coolant injection, in the event of a reactor coolant system pipe break, that the aforementioned statements in Section 6.3 did not appropriately reflect the available emergency core cooling equipment during shutdown cooling operations.  In other words, the combinations of emergency core cooling equipment available for automatic initiation would include one less low pressure coolant injection loop. The licensee entered this issue into their corrective actions program as Condition Report CR-GGN-2011-01631.  The licensee planned to take actions to update the updated final safety analysis report at the next scheduled revision. Analysis.  The failure of licensing personnel to update the final safety analysis report to reflect the available low pressure coolant injection loops for automatic initiation during
shutdown cooling operations in Mode 3 was a performance deficiency.  This finding was evaluated using traditional enforcement because it had the potential for impacting the NRC's ability to perform its regulatory function.  The inspectors used the NRC Enforcement Policy, dated September 30, 2010, to evaluate the significance of this
violation.  Consistent with the NRC Enforcement Policy, this finding was determined to be a Severity Level IV noncited violation.  This finding had no crosscutting aspect as it was associated with a traditional enforcement violation.  Enforcement.  Title 10 CFR 50.71(e)(4) requires the final safety analysis report be updated, at intervals not exceeding 24 months, and states in part, "the revisions must reflect all changes made in the facility or procedures described in the FSAR."  Contrary
to the above, licensing personnel failed to update the original revision of the final safety analysis report to reflect the actual number of low pressure coolant injection loops available for automatic initiation during shutdown cooling operations in Mode 3. 
Because the finding is of very low safety significance and has been entered into the corrective action program as Condition Report CR-GGN-2011-01631, this violation is being treated as a noncited violation consistent with the NRC Enforcement Policy:  NCV 0500416/20011002-02, "Failure to Update Available Low Pressure Coolant Injection Loops in the Updated Final Safety Analysis Report."  .2  Failure to Demonstrate Maintenance Effectiveness of Train B Control Room Air Conditioner Introduction.  The inspectors identified a Green noncited violation of 10 CFR Part 50.65(a)(2) for the failure to demonstrate that the performance of the train B control room air conditioner was being effectively controlled through the performance of appropriate preventive maintenance. Description.  On March 2, 2011, the inspectors performed a maintenance effectiveness inspection of the control room air conditioning system.  Inspectors determined that on February 3, 2010, the train B control room air conditioner compressor was replaced with a remanufactured compressor as part of annual preventative maintenance of the system.  On March 27, 2010, the control room air conditioner compressor tripped on low 
  - 15 - Enclosure usable oil pressure.  The licensee's investigation revealed that the compressor pencil strainer was approximately fifty percent covered with unidentified contaminants.  Similar contaminants were identified on the oil sump strainer.  The licensee concluded that the compressor had been installed with contaminants inside the lower half of the compressor, and subsequently replaced the remanufactured compressor on April 1, 2010, with a newly rebuilt compressor.  System engineering did not classify this event as a maintenance rule functional failure even though operations had declared the train inoperable and also stated in their operability determination that it could not meet its 30 day mission time. The train B control room air conditioner compressor subsequently either tripped or failed to properly cool the control room, due to low usable oil pressure, on three separate occasions (once in April, once May, and once in June).  In response to the June failure, the licensee performed extensive maintenance on the train B control room air conditioner compressor, which included installing a five micron suction line filter in the system.  Additionally, all three events were identified as  maintenance rule functional failures attributed to foreign material fouling in the system, which would have resulted in the performance criteria being exceeded (less than or equal to two maintenance rule
functional failure events or as a repeat functional failure).  However, the site's maintenance rule coordinator informed the inspectors that the first two events in April and May were not counted toward the criteria because they were from the same cause as the June event and; therefore, they would all be counted as one failure even thought the train was returned to service each time after corrective maintenance was performed and declared operable by operations.  Additionally, on June 22, 2010, the train was
declared inoperable due to multiple Freon leaks and was classified as another maintenance rule functional failure for the train.  On August 10, 2010, the licensee performed a Maintenance Rule (a)(1) evaluation for the subject system and, based on the presentation to the expert panel by system engineering, the panel only considered two events as maintenance rule functional failures.  System engineering did not count the one failure in March or consider the two failures in April or May.  The expert panel only considered the failures in June due to low oil pressure and Freon leaks.  Therefore the expert panel concluded that, although the train B control room air conditioner system had exceeded its established performance criteria for functional failure events, a number
of effective corrective actions had been identified and implemented and additional corrective actions were not necessary; therefore, the subject system was allowed to
retain its (a)(2) status. The train B control room air conditioner compressor subsequently either tripped or failed to properly cool the control room, due to low usable oil pressure, on two separate occasions (once in September and once in October).  The October trip of the subject
system compressor occurred while the train A control room air conditioner was out of service for routine maintenance.  The compressor pencil strainer and sump strainer were again identified with contaminants on them.  The licensee was required to make an eight-hour report to the NRC and submit a licensee event report due to both trains of control room air conditioner being inoperable.  The licensee's root cause analysis failed to identify that the train B control room air conditioner performance had not been demonstrated through the performance of appropriate preventative maintenance; nor did the root cause identify that the licensee failed to set goals and monitor the system as 
  - 16 - Enclosure required by 10 CFR 50.65(a)(1).  The train B control room air conditioner was ultimately moved into (a)(1) status on February 4, 2011, after the subject compressor again tripped due to low oil pressure on December 13, 2010.  After this trip and upon further evaluation, the licensee performed an additional corrective action that installed an in line suction filter with smaller filtering diameter and larger surface area to remove foreign material from the system.  They also modified the operator rounds to obtain daily readings of differential pressure across this new filter and through calculation, determined a differential pressure necessary for the filter to be changed out and the unit to be inspected for foreign materials. The licensee entered this issue into their corrective actions program as Condition Report CR-GGN-2011-01623.  From installation of the new inline suction filter to the conclusion of the inspection period, no additional trips of train B control room air conditioning have occurred. Analysis.  The inspectors determined that the failure to demonstrate that the performance of the train B control room air conditioner was being effectively controlled through the performance of appropriate preventive maintenance was a performance deficiency.  The finding was more than minor because it was associated with the equipment performance attribute of the Mitigating Systems Cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences.  Inspectors performed a Phase 1 screening, in accordance with Inspection Manual Chapter 0609, Attachment 4, "Phase 1 - Initial Screening and Characterization of Findings," and determined that the finding was of very low safety significance (Green)
because it did not result in a loss of system safety function since the train A control room air conditioner remained operable.  This finding had a crosscutting aspect in the area of human performance associated with the decision making component because licensee personnel failed to make appropriate safety-significant or risk-significant decisions to address the multiple failures of the train B CRAC compressor. [H.1(a)] Enforcement.  Title 10 CFR 50.65(a)(2), states, in part, that "monitoring as specified in paragraph (a)(1) of this section is not required where it has been demonstrated that the performance or condition of a structure, system, or component is being effectively controlled through the performance of appropriate preventative maintenance, such that the structure, system, or component remains capable of performing its intended function."  Contrary to the above, from March 2010 to February 2011, the licensee failed to demonstrate that the performance of the train B control room air conditioning system
was effectively controlled through the performance of appropriate preventative maintenance.  This finding was entered into the licensee's corrective action program as Condition Report CR-GGN-2011-01623.  Because this finding was determined to be of very low safety significance and was entered into the licensee's corrective action
program, this violation is being treated as a noncited violation consistent with the NRC Enforcement Policy: NCV 05000285/2011002-03, "Failure to Demonstrate Maintenance Effectiveness of Train B Control Room Air Conditioner." 
  - 17 - Enclosure 1R13 Maintenance Risk Assessments and Emergent Work Control (71111.13) a. The inspectors reviewed licensee personnel's evaluation and management of plant risk for the maintenance and emergent work activities affecting risk-significant and safety-related equipment listed below to verify that the appropriate risk assessments were performed prior to removing equipment for work: Inspection Scope  On January 9, 2011, during an ice storm requiring the plant to enter a yellow risk condition and enter their off normal event procedure for severe weather.  On February 3, 2011, during an ice storm requiring the plant to enter a yellow risk condition and enter their off normal event procedure for severe weather.  The weather required the site to cancel work and monitor their safety related standby service water system for icing conditions.  On February 9, 2011, during a winter storm, while a divisions 1 diesel generator and residual heat removal A were out for planned maintenance outage requiring the plant to enter orange risk.  On February 28, 2011, during the accidental unearthing of energized plant service water pump cables, no consequence to the plant but resulted in work
stoppage and evaluation of risk status for the site.  On March 8-9, 2011, with an emergent issue with the division 1 diesel generator and a tornado watch issued for the area requiring the plant to enter yellow risk.  The site entered their severe weather off normal procedure; this procedure
required the site to secure from half scram surveillances. 
The inspectors selected these activities based on potential risk significance relative to the reactor safety cornerstones.  As applicable for each activity, the inspectors verified that licensee personnel performed risk assessments as required by 10 CFR 50.65(a)(4) and that the assessments were accurate and complete.  When licensee personnel performed emergent work, the inspectors verified that the licensee personnel promptly assessed and managed plant risk.  The inspectors reviewed the scope of maintenance work, discussed the results of the assessment with the licensee's probabilistic risk analyst or shift technical advisor, and verified plant conditions were consistent with the risk assessment.  The inspectors also reviewed the technical specification requirements and inspected portions of redundant safety systems, when applicable, to verify risk analysis assumptions were valid and applicable requirements were met.  Specific
documents reviewed during this inspection are listed in the attachment. 
These activities constitute completion of five emergent work control inspection samples as defined in Inspection Procedure 71111.13-05. 
  - 18 - Enclosure b. No findings were identified. Findings  1R15 Operability Evaluations (71111.15) a. The inspectors reviewed the following issues: Inspection Scope  Division 3 high pressure core spray diesel generator outside air fan temperature switch fluctuating  Train A standby service water drift eliminator support base plate corrosion and missing brass bolts  Train A standby service water valve P41-F299A flange degradation  Residual heat removal equipment area temperature high/inoperable due to temperature switch  Site fire truck inoperable    Division 1 diesel generator auxiliary oil pump not obtaining procedural pressures during pre-lube prior to surveillance run  The inspectors selected these potential operability issues based on the risk significance of the associated components and systems.  The inspectors evaluated the technical adequacy of the evaluations to ensure that technical specification operability was properly justified and the subject component or system remained available such that no unrecognized increase in risk occurred.  The inspectors compared the operability and design criteria in the appropriate sections of the technical specifications and UFSAR to the licensee personnel's evaluations to determine whether the components or systems were operable.  Where compensatory measures were required to maintain operability, the inspectors determined whether the measures in place would function as intended and were properly controlled.  The inspectors determined, where appropriate, compliance with bounding limitations associated with the evaluations.  Additionally, the
inspectors also reviewed a sampling of corrective action documents to verify that the licensee was identifying and correcting any deficiencies associated with operability evaluations.  Specific documents reviewed during this inspection are listed in the
attachment. 
These activities constitute completion of six operability evaluations inspection samples as defined in Inspection Procedure 71111.15-04 
  - 19 - Enclosure b. No findings were identified. Findings  1R18 Plant Modifications (71111.18) a. To verify that the safety functions of important safety systems were not degraded, the inspectors reviewed the following temporary modifications: Inspection Scope  Temporary Modification for RWCU A/B Leak Detection (EC 22625 & EC 22635) 
Temporary Modification to install bypass signals for 'B' first stage Pressure Sensor (EC22768)  The inspectors reviewed the temporary modifications and the associated safety-evaluation screening against the system design bases documentation, including the updated final safety analysis report and the technical specifications, and verified that the modification did not adversely affect the system operability/availability.  The inspectors
also verified that the installation and restoration were consistent with the modification documents and that configuration control was adequate.  Additionally, the inspectors verified that the temporary modification was identified on control room drawings, appropriate tags were placed on the affected equipment, and licensee personnel evaluated the combined effects on mitigating systems and the integrity of radiological barriers. 
These activities constitute completion of two samples for temporary plant modifications as defined in Inspection Procedure 71111.18-05.  b. No findings were identified. Findings  1R19 Postmaintenance Testing (71111.19) a. The inspectors reviewed the following postmaintenance activities to verify that procedures and test activities were adequate to ensure system operability and functional capability: Inspection Scope  For standby liquid B after a maintenance outage  For reactor protection motor generator B after required maintenance  For residual heat removal system A after a maintenance outage 
  - 20 - Enclosure  For standby service water system A after a maintenance outage  For division 1 diesel generator after a maintenance outage  For high pressure core spray minimum flow valve 1E22-F012 after corrective maintenance  The inspectors selected these activities based upon the structure, system, or component's ability to affect risk.  The inspectors evaluated these activities for the following (as applicable):  The effect of testing on the plant had been adequately addressed; testing was adequate for the maintenance performed  Acceptance criteria were clear and demonstrated operational readiness; test
instrumentation was appropriate 
The inspectors evaluated the activities against the technical specifications, the UFSAR, 10 CFR Part 50 requirements, licensee procedures, and various NRC generic
communications to ensure that the test results adequately ensured that the equipment met the licensing basis and design requirements.  In addition, the inspectors reviewed corrective action documents associated with postmaintenance tests to determine whether the licensee was identifying problems and entering them in the corrective action program and that the problems were being corrected commensurate with their
importance to safety.  Specific documents reviewed during this inspection are listed in the attachment.  These activities constitute completion of six postmaintenance testing inspection samples as defined in Inspection Procedure 71111.19-05.  b. No findings were identified. Findings  1R22 Surveillance Testing (71111.22) a.  Inspection Scope The inspectors reviewed the UFSAR, procedure requirements, and technical specifications to ensure that the surveillance activities listed below demonstrated that the systems, structures, and/or components tested were capable of performing their intended safety functions.  The inspectors either witnessed or reviewed test data to verify that the significant surveillance test attributes were adequate to address the following:  Preconditioning 
  - 21 - Enclosure  Evaluation of testing impact on the plant  Acceptance criteria  Test equipment 
Procedures  Test data  Testing frequency and method demonstrated technical specification operability 
Test equipment removal  Restoration of plant systems 
Updating of performance indicator data  Engineering evaluations, root causes, and bases for returning tested systems, structures, and components not meeting the test acceptance criteria were correct  Reference setting data 
Annunciators and alarms setpoints  The inspectors also verified that licensee personnel identified and implemented any needed corrective actions associated with the surveillance testing.    On January 7, 2011, reactor coolant system leakage detection surveillance    On February 4, 2011, inservice test of residual heat removal system B quarterly  On February 23, 2011, reactor coolant routine chemistry surveillance  On March 2, 2011, fuel handling area ventilation exhaust radiation monitor time response test  On March 10, 2011, division 1 diesel generator monthly surveillance  On March 18, 2011, division 3 diesel generator monthly surveillance  On March 20-21, 2011, functional checks with reactor core isolation cooling valves at the remote shutdown panel  Specific documents reviewed during this inspection are listed in the attachment. 
  - 22 - Enclosure These activities constitute completion of seven surveillance (one reactor coolant system leakage detection, one inservice test, and five routine tests) testing inspection samples as defined in Inspection Procedure 71111.22-05.  b. No findings were identified.  Findings  Cornerstone:  Emergency Preparedness 1EP6 Drill Evaluation (71114.06) .1 Emergency Preparedness Drill Observation a. The inspectors evaluated the conduct of a routine licensee emergency drill on March 3, 2011, to identify any weaknesses and deficiencies in classification, notification, and protective action recommendation development activities.  The inspectors observed emergency response operations in the simulator control room and emergency operations facility to determine whether the event classification, notifications, and protective action recommendations were performed in accordance with procedures.  The inspectors also attended the licensee drill critique to compare any inspector-observed weakness with those identified by the licensee staff in order to evaluate the critique and
to verify whether the licensee staff was properly identifying weaknesses and entering them into the corrective action program.  As part of the inspection, the inspectors reviewed the drill package and other documents listed in the attachment. Inspection Scope 
These activities constitute completion of one sample as defined in Inspection Procedure 71114.06-05.  b. No findings were identified. Findings  2. RADIATION SAFETY  Cornerstone:  Occupational and Public Radiation Safety  2RS01 Radiological Hazard Assessment and Exposure Controls (71124.01)  a.  Inspection Scope This area was inspected to:  (1) review and assess licensee's performance in assessing the radiological hazards in the workplace associated with licensed activities and the implementation of appropriate radiation monitoring and exposure control measures for both individual and collective exposures, (2) verify the licensee is properly identifying and reporting Occupational Radiation Safety Cornerstone performance indicators, and 
  - 23 - Enclosure (3) identify those performance deficiencies that were reportable as a performance indicator and which may have represented a substantial potential for overexposure of the worker.  The inspectors used the requirements in 10 CFR Part 20, the technical specifications, and the licensee's procedures required by technical specifications as criteria for determining compliance.  During the inspection, the inspectors interviewed the radiation protection manager, radiation protection supervisors, and radiation workers.  The inspectors performed walkdowns of various portions of the plant, performed independent radiation dose rate measurements and reviewed the following items:  Performance indicator events and associated documentation reported by the licensee in the Occupational Radiation Safety Cornerstone  The hazard assessment program, including a review of the license's evaluations of changes in plant operations and radiological surveys to detect dose rates, airborne radioactivity, and surface contamination levels  Instructions and notices to workers, including labeling or marking containers of radioactive material, radiation work permits, actions for electronic dosimeter alarms, and changes to radiological conditions  Programs and processes for control of sealed sources and release of potentially contaminated material from the radiologically controlled area, including survey performance, instrument sensitivity, release criteria, procedural guidance, and sealed source accountability  Radiological hazards control and work coverage, including the adequacy of surveys, radiation protection job coverage, and contamination controls; the use of electronic dosimeters in high noise areas; dosimetry placement; airborne radioactivity monitoring; controls for highly activated or contaminated materials (non-fuel) stored within spent fuel and other storage pools; and posting and physical controls for high radiation areas and very high radiation areas  Radiation worker and radiation protection technician performance with respect to radiation protection work requirements  Audits, self-assessments, and corrective action documents related to radiological hazard assessment and exposure controls since the last inspection  Specific documents reviewed during this inspection are listed in the attachment.  These activities constitute completion of the one required sample as defined in Inspection Procedure 71124.01-05. 
b.  Findings 
  - 24 - Enclosure Introduction.  The inspectors identified a Green, noncited violation of Technical Specification 5.7.2, resulting from the licensee's failure to use a qualified radiation protection technician to provide direct continuous coverage of work in a locked high radiation area.  Description.  The inspectors reviewed Condition Report CR-GGN-2011-00655, which documented the identification by Cooper Nuclear Station that a contractor seeking employment as a radiation protection technician did not meet ANSI 18.1 requirements.  The finding, documented February 2, 2011, was discussed with Entergy sites during a teleconference.  Then, Grand Gulf Nuclear Station determined the individual had been employed as a radiation protection technician at Grand Gulf Nuclear Station during Refueling Outage 17, conducted in April and May 2010.  In response, Grand Gulf Nuclear Station reviewed the radiation surveys performed by the individual (from April 15 through May 13, 2010), concluded the surveys contained "data comparable with that documented in other surveys in the same areas under similar conditions," and closed the
condition report on February 8, 2011.  The inspectors reviewed the radiation survey records included in the condition report and noted something the licensee had not addressed.  On April 27, 2010, the individual had provided job coverage for work in a locked high radiation area (an area with dose rates greater than 1000 mrem/hour). Survey GG-1004-0660 identified the work area as the 128-foot auxiliary pipe chase, above the reactor water cleanup pump rooms.  Since the individual used by the licensee to provide job coverage and surveillance in a locked high radiation area was not a qualified radiation protection technician, the inspectors identified this as a performance deficiency.    Analysis.  The failure to use a qualified radiation protection technician to provide direct continuous coverage of work in a locked high radiation area is a performance deficiency.  The finding was more than minor because it was associated with the Occupational Radiation Safety Cornerstone attribute (exposure control) of program and process and affected the cornerstone objective, in that, the failure to use qualified radiation protection technicians to provide job coverage in a high radiation area with dose rates in excess of 1000 mrem/hr had the potential to increase personnel dose.  Using the Occupational Radiation Safety Significance Determination Process, the inspectors determined the finding to have very low safety significance because: (1) it was not associated with ALARA planning or work controls, (2) there was no overexposure, (3) there was no substantial potential for an overexposure, and (4) the ability to assess dose was not compromised.  The inspectors identified no cross-cutting aspect associated with this finding.  Enforcement.  Technical Specification 5.7.2, controls for high radiation areas with dose rates greater than 1000 mrem/hour, consists of all the controls for high radiation areas (Technical Specification 5.7.1) plus it requires doors to the area remain locked except during periods of access by personnel under an approved radiation work permit that shall specify the dose rate levels in the immediate work areas and the maximum allowable stay times for individuals in those areas.  In lieu of the stay time specification for the radiation work permit, direct or remote continuous surveillance may be made by personnel qualified in radiation protection procedures to provide positive exposure 
  - 25 - Enclosure control over the activities being performed within the area.  Contrary to the above, during work in an area with dose rates greater than 1000 mrem/hour on April 27, 2010, in lieu of the stay time specification for the radiation work permit, direct or remote surveillance was not made by personnel qualified in radiation protection procedures to provide positive exposure control over the activities being performed within the area.  Instead, an unqualified person was assigned to provide surveillance of a locked high radiation on April 27, 2010.  The licensee initiated Condition Report CR-GGN-2011-01045 to document the fact that it failed to identify this performance deficiency as part of the review associated with the closure of Condition Report CR-GGN-2011-00655. Because the violation was of very low safety significance and it was entered into the licensee's corrective action program, the violation is being treated as a noncited
violation, consistent with the enforcement policy.  NCV 05000416/2011002-04, "Failure to Use a Qualified Radiation Protection Technician to Provide Direct Continuous Coverage of Work in a Locked High Radiation Area."  2RS02 Occupational ALARA Planning and Controls (71124.02) 
a.  Inspection Scope This area was inspected to assess performance with respect to maintaining occupational individual and collective radiation exposures as low as is reasonably achievable (ALARA).  The inspectors used the requirements in 10 CFR Part 20, the technical specifications, and the licensee's procedures required by technical specifications as criteria for determining compliance.  During the inspection, the inspectors interviewed licensee personnel and reviewed the following items:  Site-specific ALARA procedures and collective exposure history, including the current 3-year rolling average, site-specific trends in collective exposures, and source-term measurements  ALARA work activity evaluations/postjob reviews, exposure estimates, and exposure mitigation requirements    The methodology for estimating work activity exposures, the intended dose outcome, the accuracy of dose rate and man-hour estimates, and intended versus actual work activity doses and the reasons for any inconsistencies    Records detailing the historical trends and current status of tracked plant source terms and contingency plans for expected changes in the source term due to changes in plant fuel performance issues or changes in plant primary chemistry  Radiation worker and radiation protection technician performance during work activities in radiation areas, airborne radioactivity areas, or high radiation areas  Audits, self-assessments, and corrective action documents related to ALARA planning and controls since the last inspection 
  - 26 - Enclosure Specific documents reviewed during this inspection are listed in the attachment.  These activities constitute completion of the one required sample as defined in Inspection Procedure 71124.02-05.  b.  Findings No findings were identified. 4. OTHER ACTIVITIES 4OA1 Performance Indicator Verification (71151) .1 Data Submission Issue a. The inspectors performed a review of the performance indicator data submitted by the licensee for the fourth Quarter 2010 performance indicators for any obvious inconsistencies prior to its public release in accordance with Inspection Manual
Chapter 0608, "Performance Indicator Program." Inspection Scope  This review was performed as part of the inspectors' normal plant status activities and, as such, did not constitute a separate inspection sample. 
b. No findings were identified.  Findings  .2 Unplanned Scrams per 7000 Critical Hours (IE01) a. The inspectors sampled licensee submittals for the unplanned scrams per 7000 critical hours performance indicator for the period from the first quarter 2010 through the fourth quarter 2010.  To determine the accuracy of the performance indicator data reported during those periods, the inspectors used definitions and guidance contained in NEI Document 99-02, "Regulatory Assessment Performance Indicator Guideline," Revision 6.  The inspectors reviewed the licensee's operator narrative logs, condition reports, event reports, and NRC integrated inspection reports for the period of January 2010 through December 2010 to validate the accuracy of the submittals.  The inspectors also reviewed the licensee's condition report database to determine if any problems had been identified with the performance indicator data collected or transmitted for this indicator and none were identified.  Specific documents reviewed are described in the attachment to this report. Inspection Scope  These activities constitute completion of one unplanned scrams per 7000 critical hours sample as defined in Inspection Procedure 71151-05. 
  - 27 - Enclosure  b. No findings were identified. Findings  .3 Unplanned Scrams with Complications (IE02) a. The inspectors sampled licensee submittals for the unplanned scrams with complications performance indicator for the period from first quarter 2010 through the fourth quarter 2010.  To determine the accuracy of the performance indicator data reported during those periods, the inspectors used definitions and guidance contained in NEI Document 99-02, "Regulatory Assessment Performance Indicator Guideline," Revision 6.  The inspectors reviewed the licensee's operator narrative logs, condition reports, event reports, and NRC integrated inspection reports for the period of January 2010 through December 2010 to validate the accuracy of the submittals.  The inspectors also reviewed the licensee's condition report database to determine if any problems had been identified with the performance indicator data collected or transmitted for this indicator and none were identified.  Specific documents reviewed are described in the attachment to this report. Inspection Scope 
These activities constitute completion of one unplanned scrams with complications sample as defined in Inspection Procedure 71151-05.  b. No findings were identified. Findings  .4 Unplanned Power Changes per 7000 Critical Hours (IE03) a. The inspectors sampled licensee submittals for the unplanned power changes per 7000 critical hours performance indicator for the period from first quarter 2010 through the fourth quarter 2010.  To determine the accuracy of the performance indicator data reported during those periods, the inspectors used definitions and guidance contained in NEI Document 99-02, "Regulatory Assessment Performance Indicator Guideline," Revision 6.  The inspectors reviewed the licensee's operator narrative logs, condition reports, event reports, and NRC integrated inspection reports for the period of January 2010 through December 2010 to validate the accuracy of the submittals.  The inspectors also reviewed the licensee's condition report database to determine if any problems had been identified with the performance indicator data collected or transmitted for this indicator and none were identified.  Specific documents reviewed are described in the attachment to this report. Inspection Scope 
These activities constitute completion of one unplanned transients per 7000 critical hours sample as defined in Inspection Procedure 71151-05. 
  - 28 - Enclosure  b. No findings were identified. Findings  .5 Occupational Exposure Control Effectiveness (OR01)  a.  Inspection Scope The inspectors reviewed performance indicator data for the second quarter of 2010
through the fourth quarter of 2010.  The objective of the inspection was to determine the accuracy and completeness of the performance indicator data reported during these periods.  The inspectors used the definitions and clarifying notes contained in NEI
Document 99-02, "Regulatory Assessment Performance Indicator Guideline," Revision 6, as criteria for determining whether the licensee was in compliance.    The inspectors reviewed corrective action program records associated with high radiation area (greater than 1 rem/hr) and very high radiation area non-conformances.  The inspectors reviewed radiological, controlled area exit transactions greater than 100 mrem.  The inspectors also conducted walkdowns of high radiation areas (greater than 1 rem/hr) and very high radiation area entrances to determine the adequacy of the controls of these areas. 
These activities constitute completion of the occupational exposure control effectiveness sample as defined in Inspection Procedure 71151-05.  b.  Findings No findings were identified.  .6 Radiological Effluent Technical Specifications/Offsite Dose Calculation Manual Radiological Effluent Occurrences (PR01)  a.  Inspection Scope The inspectors reviewed performance indicator data for the second quarter of 2010 through the fourth quarter of 2010. The objective of the inspection was to determine the accuracy and completeness of the performance indicator data reported during these periods.  The inspectors used the definitions and clarifying notes contained in NEI Document 99-02, "Regulatory Assessment Performance Indicator Guideline," Revision 6, as criteria for determining whether the licensee was in compliance.    The inspectors reviewed the licensee's corrective action program records and selected individual annual or special reports to identify potential occurrences such as
unmonitored, uncontrolled, or improperly calculated effluent releases that may have impacted offsite dose.   
  - 29 - Enclosure These activities constitute completion of the radiological effluent technical specifications/offsite dose calculation manual radiological effluent occurrences sample as defined in Inspection Procedure 71151-05.  b.  Findings No findings were identified.  4OA2 Identification and Resolution of Problems (71152) Cornerstones:  Initiating Events, Mitigating Systems, Barrier Integrity, Emergency Preparedness, Public Radiation Safety, Occupational Radiation Safety, and Physical Protection .1 Routine Review of Identification and Resolution of Problems a. As part of the various baseline inspection procedures discussed in previous sections of this report, the inspectors routinely reviewed issues during baseline inspection activities and plant status reviews to verify that they were being entered into the licensee's corrective action program at an appropriate threshold, that adequate attention was being given to timely corrective actions, and that adverse trends were identified and addressed.  The inspectors reviewed attributes that included the complete and accurate identification of the problem; the timely correction, commensurate with the safety significance; the evaluation and disposition of performance issues, generic implications, common causes, contributing factors, root causes, extent of condition reviews, and previous occurrences reviews; and the classification, prioritization, focus, and timeliness
of corrective actions.  Minor issues entered into the licensee's corrective action program because of the inspectors' observations are included in the attached list of documents reviewed. Inspection Scope  These routine reviews for the identification and resolution of problems did not constitute any additional inspection samples.  Instead, by procedure, they were considered an integral part of the inspections performed during the quarter and documented in
Section 1 of this report. 
b. No findings were identified. Findings  .2 Daily Corrective Action Program Reviews a. In order to assist with the identification of repetitive equipment failures and specific human performance issues for follow-up, the inspectors performed a daily screening of Inspection Scope 
  - 30 - Enclosure items entered into the licensee's corrective action program.  The inspectors accomplished this through review of the station's daily corrective action documents.  The inspectors performed these daily reviews as part of their daily plant status monitoring activities and, as such, did not constitute any separate inspection samples.  b. No findings were identified. Findings  .3 Selected Issue Follow-up Inspection a. During a review of items entered in the licensee's corrective action program, the inspectors recognized CR-GGN- 2009-05879 a corrective action item documenting temperature switches for safety related ventilation system.  The inspectors reviewed that item as described in Inspection Procedure 71152.02 to verify, in part, licensee evaluation and disposition of operability and reportability issues; consideration of extent of condition and cause, generic implications, common cause, and previous occurrences; classification and prioritization of the problem's resolution commensurate with the safety significance; and identification of corrective actions that were appropriately focused to correct the problem. Inspection Scope  These activities constitute completion of one in-depth problem identification and resolution sample as defined in Inspection Procedure 71152-05.  b. No findings were identified. Findings  4OA3 Event Follow-up (71153) .1 (Closed) LER 05000416/2010-002-00, "Control Room Air Conditioning Inoperability - Loss of Both Trains" a. On October 14, 2010, while operating at approximately 100 percent power, the train B
control room air conditioner subsystem tripped on low oil pressure while the train A control room air conditioner subsystem was out of service for maintenance.  The control room temperature increased and actions were taken to maintain control room temperatures below the technical specification limit of 90 degrees Fahrenheit.  The two control room air conditioning subsystems were inoperable for 64 hours and 24 minutes until the train A control room air conditioner was declared operable.  Inspection Scope The three possible failure mechanisms that the licensee identified in their root cause evaluation were 1) the intermittent failure of the low oil differential pressure switch, 2) the 
  - 31 - Enclosure intermittent failure of one or more loading/unloading mechanisms, and 3) one or more of the temperature control valves were in an open condition or in a more than desired open position.  The licensee also identified a contributing cause of failure to exclude foreign material during maintenance activities on the train B control room air conditioner.  Inspectors reviewed the circumstances surrounding the event, the licensee's response
to the event, and the licensee's corrective actions to preclude repetition.  Documents reviewed as part of this inspection are listed in the attachment.  The enforcement aspects of this finding are discussed in this section and in Section 1R12.  This LER is closed. b. Findings Introduction.  The inspectors reviewed a self-revealing, Green noncited violation of 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, after the licensee failed to determine the cause and prevent recurrence of a significant condition adverse to quality associated with the train B control room air conditioner compressor tripping due to low oil pressure. Description.  On October 14, 2010, the train B control room air conditioner subsystem tripped on low oil pressure while the train A control room air conditioner subsystem was
out of service for maintenance.  The control room temperature increased, and actions were taken to maintain control room temperatures below the technical specification limit of 90 degrees Fahrenheit.  The licensee determined that the event (i.e., one subsystem inoperable and unavailable for maintenance while the other subsystem was inoperable due to a trip) was reportable to the NRC.  The two control room air conditioning subsystems were inoperable for 64 hours and 24 minutes until the train A control room air conditioner was declared operable.  This was a significant condition because it rendered technical specification required equipment inoperable. The licensee's corrective actions to address the event involved performing a root cause evaluation.  The licensee concluded that the three possible failure mechanisms were 1) an intermittent failure of low oil differential pressure switch, 2) an intermittent failure of one or more loading/unloading mechanisms, and 3) failure of one or more thermal expansion valves.  The licensee also concluded that a contributing cause of the event was the failure to exclude foreign material during maintenance activities of the system.  The licensee addressed each of the possible root causes, as well as the contributing cause, since a single root cause could not be determined.  The corrective action for the three probable root causes included 1) ensuring that only original differential pressure switches are used (or a suitable equivalent) for replacement; 2) revising planned
maintenance tasks to included instructions for the loader/unloader disassembly, inspection and reassembly; 3) revising tasks for compressor A and B rebuilds; and 4) revising compressor preventative maintenance tasks to record the degree of superheat for each thermal expansion valve. Despite the corrective actions implemented by the licensee, the train B control room air
conditioner compressor again tripped on December 13, 2010, due to low oil pressure.  After this trip and upon further evaluation, the licensee performed an additional corrective action that installed an inline suction filter with smaller filtering diameter and 
  - 32 - Enclosure larger surface area to remove foreign material from the system.  The licensee also modified the operator rounds to obtain daily readings of differential pressure across this new filter and through calculation, determined a differential pressure necessary to change the filter.  The condition report that documented the December 13th event was closed to the corrective actions associated with the October 14th compressor trip and the new corrective action associated with the newly installed in line suction filter. The licensee entered this event into their corrective actions program as condition report CR-GGN-2010-07315.  Since the use of the new inline suction filter, they have not had any additional trips of the control room air conditioning B.  The April 2011 inspection showed that the filter had reduced foreign material on the compressor suction strainer by
40 percent from the March 2011 inspection.  Also in May 2011, the licensee plans to boroscope the evaporation section of the air conditioner to search for any other foreign material. Analysis.  The inspectors determined that the failure to take corrective actions to prevent recurrence of the train B control room air conditioner compressor tripping due to low oil pressure was a performance deficiency.  This finding was more than minor because it was associated with the equipment performance attribute of the Mitigating Systems Cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences.  Using Inspection Manual Chapter 0609, "Significance Determination Process," Phase 1 worksheets, the inspectors determined that a Phase 2 estimate was required because the finding represented a loss of system safety function.  The plant-specific risk informed notebook does not include the evaluation of risk caused by the loss of cooling to the main control room.  Therefore, the senior reactor analyst conducted a Phase 3 analysis. The analyst noted that understanding the risk affect of control room chillers required a review of the following items:  Loss of offsite power frequency LOOP):  Several alternative methods of cooling control room equipment are available provided offsite power is available.  Therefore, the dominant risk impact of essential chillers is during a loss of offsite power.  The loss of offsite power frequency documented in the plant-specific SPAR model is 3.59 x 10-2/year.  Loss of the opposite train probability (PCH-A):  The performance deficiency only affected Train B CRAC.  Therefore, the Train A would still be available to cool the
main control room.  The generic failure probability for a single train of safety-related equipment is approximately 3 x 10-2/demand.  Exposure Period (EXP):  Although the Train B CRAC system was placed in service without correcting the failure mechanism on November 1, 2010, the
chiller continued to be utilized and run for much of the time until failure on December 13, 2010.  The analyst noted that the chiller ran from November 12 until it failed on December 13, 2010.  Therefore, the time that the chiller was actually unavailable to perform it's 24-hour risk significant mission time was 
  - 33 - Enclosure about 48 hours (the last 24 hours of its run and the 24 hours it took to repair).  This gave an exposure time of 2 days.  Conditional Core Damage Probability (CCDP):  In the worst case failure of control room air conditioning would result in main control room abandonment. 
The generic CCDP for shutting the reactor down from outside the main control room is approximately 0.1.  The analyst determined that a bounding assessment of the change in core damage    LOOP  *  PCH-A  *  EXP  *  CCDP    =  3.59 x 10-2/year  *  3 x 10-2/demand  *  2 days/365 days/year  *  0.1  =  5.9 x 10-7  Based on the above bounding analysis, the analyst determined that the change in core damage frequency result was 5.9 x 10-7.  This noncited violation was therefore determined to be of very low safety significance (Green).  This finding had a crosscutting aspect in the area of problem identification and resolution associated with the corrective action program component because licensee personnel failed to thoroughly evaluate the multiple failures of the train B control room air conditioner compressor. [P.1(c)] Enforcement.  Title 10 CFR Part 50, Appendix B, Criterion XVI, "Corrective Action," states, in part, that in the case of a significant condition adverse to quality, "measures shall assure that the cause of the condition is determined and corrective action taken to preclude repetition." Contrary to the above, plant personnel did not implement corrective actions to preclude repetition of a significant condition adverse to quality associated with the tripping of the train B control room air conditioning compressor due to low oil
pressure.  Specifically, on December 13, 2010, the train B control room air conditioner compressor tripped due to low oil pressure after the licensee had a performed a root cause analysis to identify the cause and prevent recurrence of the compressor tripping due to low oil pressure.  Because the finding was of very low safety significance and has been entered into the corrective action program as Condition Report CR-GGN-2010-07315, this violation is being treated as a noncited violation, consistent with the NRC
Enforcement Policy.  NCV 05000416/2011002-05, "Failure to Prevent Recurrence of Control Room Air Conditioner Compressor Tripping Due to Low Oil Pressure." .2  Steam Leak in the Containment  a. On November 8, 2010, the inspectors responded to the control room to observe operator response to a steam leak in containment. The newly installed mitigation monitoring system positive displacement pump ejected the cylinder causing an approximate seven gallons per minute reactor coolant leak. The inspectors observed operator actions, control room briefs and overall plant response to the event. The inspectors also Inspection Scope 
  - 34 - Enclosure observed control room indications used to identify abnormal conditions in the containment building. Documents reviewed for this inspection are listed in the attachment.  b.      Findings  Introduction.  The inspectors reviewed a self-revealing, Green finding of EN-DC-115, "Engineering Change Process," involving the failure to maintain adequate design control measures associated with the installation of the mitigation monitoring system. Description.  On November 8, 2010, at approximately 5:30 am, a reactor coolant pressure boundary failure occurred at the skid mounted Online Noble Chemical - Mitigation Monitoring System pump inside primary containment.  The positive displacement sample pump ejected the pump piston from the housing resulting in an approximate 7 gpm leak of reactor coolant. The leak was not detected for approximately 4.5 hours, resulting in the release of approximately 2,000 gallons of reactor coolant which flashed directly to steam. The steam leak resulted in a reactor recirculation system
flow control valve lockup (due to HPU motor failure) and approximately 15,000 square feet of contaminated area in the primary containment structure. The inspectors reviewed the mitigation monitoring system modification documentation and found that the design documentation did not appropriately address the design requirements for the installation of the mitigation monitoring system pump.  The licensee failed to ensure proper validation testing for the pump prior to installation in the plant. 
Specifically, they did not ensure that the pump would be able to withstand the system operating pressures and temperatures in which it was installed.  They failed to validate the design, which had a single point vulnerability, that resulted in the piston injecting from the pump and caused the leakage and contamination of the containment.  In addition, the inspectors reviewed the root cause analysis of the event and found that the licensee failed to apply the appropriate oversight of the engineering vendor due to weaknesses in the procedure EN-DC-114, "Vendor Quality Management/Oversight." The licensee entered this event into their corrective actions program as condition report CR-GGN-2010-07852.  The licensee has currently removed the mitigation monitoring system pump from the plant, and isolated the mitigation monitoring system skid from the reactor water cleanup system.  They are evaluating the design to make appropriate
changes to ensure a repeat of this event will not occur. Analysis.  The failure to implement adequate design control measures for modifications to the plant, which impacted the reactor coolant pressure boundary, is a performance deficiency.  Specifically procedure EN-DC-115, "Engineering Change Process," step 5.1[1], requires "during the engineering change development a choice of new technology or application is an error precursor which will need to have defensive functions built into the design, testing and maintenance, including developing in-house expertise."  Contrary to this, the engineering change package that implemented this design change failed to ensure proper validation testing was performed prior to installation in the plant.  The finding is more than minor because it affects the design control attribute of the Barrier Integrity Cornerstone to provide reasonable assurance that physical design barriers 
  - 35 - Enclosure protect the public from radionuclide releases caused by accidents or events.  Therefore, using inspection Manual Chapter 0609, "Significance Determination Process," Phase 1 Worksheet for LOCA initiators, the inspectors concluded that the finding was of very low safety significance (Green) because the failure of the mitigation monitoring system would not have exceeded technical specifications limits for identified leakage in the reactor coolant system.  This finding has a crosscutting aspect in the area of human performance associated with the work practices component because the licensee failed to adequately oversee the design of the mitigation monitor system such that nuclear safety is supported. [H.4(c)] Enforcement.  No violation of regulatory requirements occurred.  This finding was entered into the licensee's corrective action program as CR-GGN-2010-07852, and is identified as: FIN 05000416/2011002-06, "Inadequate Design Control for the Mitigation Monitoring System Modification." 4OA5 Other Activities 1.  (Closed) Temporary Instruction (TI) 2515/179, "Verification of Licensee Responses to NRC Requirement for Inventories of Materials Tracked in the National Source Tracking System Pursuant to Title 10, Code of Federal Regulations, Part 20.2207 (10 CFR 20.2207)"  a. Inspection Scope  An NRC inspection was performed to confirm that the licensee has reported their initial inventories of sealed sources pursuant to 10 CFR 20.2207 and to verify that the National Source Tracking System database correctly reflects the Category 1 and 2 sealed sources in custody of the licensee.  Inspectors interviewed personnel and performed the following:  Reviewed the licensee's source inventory    Verified the presence of any Category 1 or 2 sources    Reviewed procedures for and evaluated the effectiveness of storage and handling of sources  Reviewed documents involving transactions of sources  Reviewed adequacy of licensee maintenance, posting, and labeling of nationally tracked sources  b.  Findings While comparing the National Source Tracking System database information, the Licensee's information submittal, and original source certificates, the inspector noted that the licensee erroneously reported information for one of the four sources meeting the reporting criteria.  The licensee used original leak test data and submitted the wrong 
  - 36 - Enclosure serial number and activity date for the source.  The licensee reviewed all relevant data and submitted corrected documents within the five business days allowed by 10 CFR 20.2207(g).  This finding was considered as an administrative error and of minor safety significance.  4OA6 Meetings Exit Meeting Summary On February 18, 2011, the inspectors presented the results of the radiation safety inspections to Mr. J. Browning, General Plant Manager, and other members of the licensee staff.  The licensee acknowledged the issues presented.  The inspectors asked the licensee whether any materials examined during the inspection should be considered proprietary.  No proprietary information was identified.  On April 14, 2011, the inspectors presented the inspection results to M. Perito, Site Vice-President Operations and other members of the licensee staff.  The licensee acknowledged the issues presented.  The inspector asked the licensee whether any materials examined during the inspection should be considered proprietary.  No proprietary information was identified.  4OA7 Licensee-Identified Violations The following violations of very low safety significance (Green) were identified by the licensee and are violations of NRC requirements which meet the criteria of Section 2.3.2 of the NRC Enforcement Policy for being dispositioned as noncited violations.  .1 Technical Requirements Manual (TRM) section 6.2.1 requires that fire detection instrumentation for each fire detection zone shall be operable and if the required detection system is inoperable an hourly fire watch must be established.  Contrary to this, on February 9, 2011 the licensee identified that fire detection instrumentation for fire zone 2-12 had been left in the non-audible alarm for the main control room on the fire computer when the limiting condition for operations was cleared on December 8, 2010
when zone was returned to operable status.  The control room supervisor on February 9, 2011, discovered this condition when entering a fire-limiting condition for operation for the division 1 diesel generator room to allow welding.  The licensee determined that it had been in non-audible status from December 8, 2010, through February 9, 2011.  This issue was documented in the licensee's corrective action program in condition report CR-GGN-2011-00851.  The senior reactor analyst from region IV performed a bounding evaluation of the change in risk caused by this condition.  According to the Grand Gulf Updated Final Safety Analysis Report, Fire Zone 2-12 only contains Division I equipment.  A fire that consumed the equipment in the area could not result in a loss of offsite power or other unplanned transient.  Given the ignition frequency of the area, the 60-day exposure period, and the conditional core damage probability with the loss of the Division I emergency diesel generator, the analyst calculated that the change in risk was significantly less than 1E-6.  Therefore, this finding was of very low safety significance (Green). 
  - 37 - Enclosure 
  A-1    Attachment SUPPLEMENTAL INFORMATION KEY POINTS OF CONTACT  Licensee Personnel    R. Benson, Manager (Acting), Radiation Protection  J. Browning, General Plant Manager D. Coulter, Senior Licensing Specialist H Farris, Assistant Operation Manager K. Higgenbotham, Planning and Scheduling Manager J. Houston, Maintenance Manager R. Jackson, Licensing C. Lewis, Manager, Emergency Preparedness C. Perino, Licensing Manager M. Perito, Site Vice President of Operations M. Richey, Director, Nuclear Safety Assurance F. Rosser, Supervisor, Dosimetry R. Sumrall, Superintendant, Operations Training R. Sylvan, Supervisor, Radiation Protection T. Trichell, Radiation Protection Manager D. Wiles, Engineering Director R. Wilson, Manager, Quality Assurance E. Wright, Supervisor, Radiation Protection  NRC Personnel  R. Smith, Senior Resident Inspector     
  A-2    Attachment LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED  Opened and Closed 05000416/2011002-01 NCV Transient Combustible Stored in the Fire Exclusion Zone Near the Independent Spent Fuel Storage Installation (Section 1R05) 05000416/2011002-02 NCV Failure to Update Available Low Pressure Coolant Injection Loops in the Updated Final Safety Analysis Report (Section 1R12) 05000416/2011002-03 NCV Failure to Demonstrate Maintenance Effectiveness of Train B Control Room Air Conditioner(Section 1R12) 05000416/2011002-04 NCV Failure to Use a Qualified Radiation Protection Technician to Provide Direct Continuous Coverage of Work in a Locked High Radiation Area (Section 2RS01) 05000416/2011002-05 NCV Failure to Prevent Recurrence of Control Room Air Conditioner Compressor Tripping Due to Low Oil Pressure (Section 4OA3) 05000416/2011002-06 FIN Inadequate Design Control for the Mitigation Monitoring System Modification (Section 4OA3)  Closed      TI 2515/179 TI Verification of Licensee Responses to NRC Requirement for Inventories of Materials Tracked in the National Source Tracking
System Pursuant to Title 10, Code of Federal Regulations, Part 20.2207 (10 CFR 20.2207) (Section 4OA5) 05000416/2010-002-00 LER Control Room Air Conditioning Inoperability - Loss of Both Trains (Section 4OA3) 
   
  A-3    Attachment LIST OF DOCUMENTS REVIEWED  Section 1RO1:  Adverse Weather Protection  PROCEDURE NUMBER TITLE REVISION ENS-EP-302 Severe Weather Response 11 05-1-02-VI-2 Hurricanes, Tornados, and Severe Weather 113 04-1-01-P41-1 Standby Service Water System 133 04-1-01-N71-1 Circulating Water System 72 04-1-03-A30-1 Cold Weather Protection 20  OTHER NUMBER TITLE DATE  SSW Pump Discharge Temperatures January 6-10, 2011  WORK ORDER  WO 52233022    Section 1RO4:  Equipment Alignment  PROCEDURE NUMBER TITLE REVISION 9.3-17 - 9.3-25 GG UFSAR 3 07-1-34-C41-C001-1 Standby Liquid Control Pump 10 04-1-01-C41-1 Standby Liquid Control System 119 04-1-01-P75-1 Standby Diesel Generator System 88 04-1-01-P41-1 Standby Service Water System 133 04-1-01-E12-1 System Operating Instructions Residual Heat Removal System 137 04-1-01-E12-1 Residual Heat Removal B 137 04-1-01-E12-1 Residual Heat Removal C 137 
  A-4    Attachment PROCEDURE NUMBER TITLE REVISION 04-1-01-E12-1 Residual Heat Removal B Attachment IB 137 04-1-01-E12-1 Residual Heat Removal B Attachment IIIB 137 04-1-01-E12-1 Residual Heat Removal C Attachment IC 137 04-1-01-E12-1 Residual Heat Removal B Attachment VB 137 04-1-01-E12-1 Residual Heat Removal (Interface Valves) Attachment IIE 137 04-1-01-P41-1 Standby Service Water System Attachment IIB 133 04-1-01-P41-1 Standby Service Water System Attachment IIIB 113  OTHER NUMBER TITLE DATE 11-4568  Scaffolding Evaluation Request February 15, 2001  CALCULATION NUMBER TITLE DATE 9645 Diesel Generator Building Walls August 2, 1976 C-C400 SSW CT and Basin (Pump-House) Tornado and No Earthquake May 28, 1976 C-0-100 Diesel Generator Bldg. Walls Tornado Wind Load W' August 2, 1976  WORK ORDER  WO 52256371 WO 00260559 WO 00259801  Section 1RO5:  Fire Protection  PROCEDURE NUMBER TITLE REVISION Fire Pre-Plan DG-03 Division II Diesel Generator Room 3 9A-343 - 9A347 GG UFSAR  Fire Pre-Plan A-02 RHR A Pump Room 1A103 1 
  A-5    Attachment PROCEDURE NUMBER TITLE REVISION Fire Pre-Plan A-03 RCIC Pump Room 1A104 1 Fire Pre-Plan A-04 RHR B Pump Room 1A105 1 9A.5.2.2 Safe Shutdown Equipment  Appendix 9B Fire Protection Program  CONDITION REPORT  CR-GGN-2011-00862 CR-GGN-2011-01939 CR-GGN-2011-00851 CR-GGN-2011-00455    Section 1RO6:  Flood Protection Measures  PROCEDURE NUMBER TITLE REVISION / DATE 9A-336 - 9A338 GG UFSAR  9A.5.59 GG UFSAR FIRE AREA 59  EN-OP-104 Operability Determination Process Immediate Determination For Degraded of Nonconforming Conditions 4  OTHER NUMBER TITLE DATE  Russell Daniel Oil Co. Inc. Delivery Date Schedule February 10, 2011  CONDITION REPORT  CR-GGN-2011-00198 CR-GGN-2011-00562 CR-GGN-2011-00654  WORK ORDER  WO 52281566 WO 52210679 03 WO 52210679 02 WO 52210679 01 WO 00041743 WO 52210679 
 
  A-6    Attachment ENGINEERING CHANGE  EC No. 24971 EC No. 24904 EC No. 24972  Section 1R07:  PROCEDURE NUMBER TITLE REVISION 08-S-03-10 Chemistry Procedure-Closed Loops 48  OTHER NUMBER TITLE DATE CCE 2006-0002 Commitment Change Evaluation Form  Letter Response to Generic Letter 89-13; Service Water System Problems Affecting Safety-Related Equipment January 29, 1990  WORK ORDER  WO 00178965 01 WO 00178965 02 WO 00178965 03  Section 1R11:  Licensed Operator Requalification Program  OTHER NUMBER TITLE REVISION / DATE GSMS-LOR-WEX03 LOR Training-Double Recirculation Pump Trip/ATWS January 18, 2011 Rev 17  Turnover and Simulator Differences 2011 Cycle 1 Simulator Training 1  Per Control Room Walkdown, Modifications to TREX Load January 7, 2011 Letter Emergency Preparedness January 31, 2011 Simulator Drill Performance Indicators February 1, 2011     
  A-7    Attachment Section 1R12:  Maintenance Effectiveness  PROCEDURE NUMBER TITLE REVISION / DATE EN-FP-S-001-Multi Engineering Standard-Appendix R Emergency Lighting Units January 10, 2011 07-S-12-143 Big Beam Emergency Light Inspection, Battery Capacity Verification, and Functional Test 2 EN-DC-203 Maintenance Rule Program 1 EN-DC-206 Maintenance Rule (a)(1) Process 1 EN-DC-207 Maintenance Rule Periodic Assessment 1 NMM EN-LI-118 Root Cause Evaluation Report Attachment IV (54 of 54) 12 EN-DC-205 Maintenance Rule Monitoring 2  GG UFSAR Table 7.5-1 Safety-Related Display Instrumentation  GG UFSAR Table 7.5-2 Post-Accident Monitoring Instrumentation  GG UFSAR 6.3 Emergency Core Cooling Systems 0 03-1-01-3 Integrated Operating Instructions Plant Shutdown 118  OTHER NUMBER TITLE REVISION / DATE  Emergency Lighting - GGNS Discussion of Recent Activities  Maintenance Rule Expert Panel June 22, 2010 Meeting Minutes  Maintenance Rule Expert Panel August 10, 2010 Meeting Minutes  Entergy Nuclear-GGNS Maintenance Rule Program Basis Document, Control Room and Emergency Lighting (Z92) System 0 Z92 Maintenance Rule Database Control Room and Emergency Lighting  TM M348X.8001 Midtron 3200 Battery Conductance Tester 
  A-8    Attachment OTHER NUMBER TITLE REVISION / DATE VMA97/0181 Emergency Lights  Maintenance Rule Database Information - Main Control Room Air Conditioning (Z51) System  March 21, 2009 to December 23, 2010  Maintenance Rule Database Z51 Control Room HVAC System  EC No.: 27856 Engineering Evaluation 0  Maintenance Rule Program (a)(1) Evaluation and Action Plan Main Control Room Air Conditioning (Z51) System  Agenda for Maintenance Rule Expert Panel Meeting February 4, 2010  RHR Heat Exchanger SSW Flow Indication (a)(1) Status  Maintenance Rule Database E12 RHR System  Maintenance Rule Program (a)(1) Evaluation for the Residual Heat Removal (E12/RHR) System CR-GGN-2009-0754 CA No. 002  Maintenance Rule (a)(1) Evaluation Standby Service Water (P41) System (GR-GGN-2010-00305)  Agenda Items from Maintenance Rule Expert Panel Meeting June 24, 2010  Agenda Items from Maintenance Rule Expert Panel Meeting June 22, 2010  CONDITION REPORT  CR-GGN -2009-05330 CR-GGN -2010-00381 CR-GGN -2010-04575 CR-GGN -2010-04585 CR-GGN -2010-06346 CR-GGN -2011-00481 CR-GGN -2011-00521 CR-GGN -2011-01212 CR-GGN-2011-01650 CR-GGN-2010-01984 CR-GGN-2011-11505 CR-GGN-2011-01308 CR-GGN-2010-07315 CR-GGN-2009-00842 CR-GGN-2009-00754 GR-GGN-2009-01729 CR-GGN-2009-02477 CR-GGN-2009-03394 CR-GGN-2009-02947 CR-GGN-2009-02848 CR-GGN-2009-03292 CR-GGN-2009-03574 CR-GGN-2009-03592 CR-GGN-2009-04219 
  A-9    Attachment CR-GGN-2010-01031 CR-GGN-2009-04048 CR-GGN-2009-05930 CR-GGN-2009-05215 CR-GGN-2009-05932 CR-GGN-2009-05472 CR-GGN-2009-06066 CR-GGN-2009-04733 CR-GGN-2010-00036 CR-GGN-2010-01329 CR-GGN-2011-00789 CR-GGN-2010-07351 CR-GGN-2010-04009 CR-GGN-2010-05892 CR-GGN-2011-00791 CR-GGN-2011-00820 CR-GGN-2011-00985 CR-GGN-2009-01204 CR-GGN-2010-00684 CR-GGN-2010-05290 CR-GGN-2010-01585 CR-GGN-2010-00800 CR-GGN-2010-01474 CR-GGN-2010-01337 CR-GGN-2009-05508 CR-GGN-2010-01320 CR-GGN-2010-01345 CR-GGN-2009-05731 CR-GGN-2009-06174 CR-GGN-2010-02797 CR-GGN-2010-02200 CR-GGN-2010-03655 CR-GGN-2010-04629 CR-GGN-2010-02990 CR-GGN-2010-03241 CR-GGN-2009-00350 CR-GGN-2009-00426 CR-GGN-2009-00846 CR-GGN-2009-01518 CR-GGN-2010-02805 CR-GGN-2010-04015 CR-GGN-2010-03333 CR-GGN-2010-04625 CR-GGN-2010-04255 CR-GGN-2009-05527 CR-GGN-2010-02974 CR-GGN-2010-06137 CR-GGN-2010-05208 CR-GGN-2010-05330 CR-GGN-2010-04686 CR-GGN-2010-04963 CR-GGN-2010-05572 CR-GGN-2010-03650 CR-GGN-2010-06978 CR-GGN-2010-06148 CR-GGN-2010-06150 CR-GGN-2010-05328 CR-GGN-2010-06142 CR-GGN-2011-00403 CR-GGN-2011-00749 CR-GGN-2011-00819 CR-GGN-2011-00850 CR-GGN-2010-06895 CR-GGN-2010-06918 CR-GGN-2011-01212 CR-GGN-2010-05147  WORK ORDER  WO 52255810 WO 52223396 WO 52271013 01 WO 52196016 WO 52220690  Section 1R13:  Maintenance Risk Assessment and Emergent Work Controls  PROCEDURE NUMBER TITLE REVISION EN-WM-101 On-line Work Management Process 7 EN-WM-100 Work Request Generation, Screening and Classification 5 EN-WM-101 On-line Work Management Process 8 EN-WM-101 On Line Emergent Work Addition/Deletion Approval Form for the Week of March 7, 2011 7 
  A-10    Attachment PROCEDURE NUMBER TITLE REVISION EN-WM-101 On Line Emergent Work Addition/Deletion Approval Form for the Week of February 28, 2011 7  WORK ORDER  WO250074 WO247598 WO52290243 WO52290462 WO52290463 WO52290464 WO70346 WO52291451 WO52291458 WO52291454 WO52291456 WO52291689 WO52291690 WO261213 WO52284287 WO52269835 WO52290236 WO52290463 WO52290464 WO52291844 WO52291454 WO52291456 WO261601 WO250966-02 WO237429 WO256910-01 WO52290639 WO52287735 WO52290638 WO52287736 WO52276935 WO260417 WO260212-02 WO260212-01 WO00219198 WO260529-07 WO52204865 WO260503 WO52243284 WO260529-07 WO52204865 WO52199495 WO255787-01,02,03,04 WO52249417 WO52271012 WO261175 WO259639 WO257881 WO200935-02 WO00257063 WO224859 WO261706 WO255360-08 WO263130 WO261181-01 and 02 WO262143 WO234988-04 WO234992-04 WO52250110-03 WO234985-04 WO259003-05 WO259005-05 WO259007-05 WO112951-08 WO52270042 WO52259286 WO52275616 WO52288663 WO52290468 WO52270252 WO52291424 WO52270250 WO52291423 WO235034 WO52288844 WO51563342 WO160041 WO52290473 WO52281103       
  A-11    Attachment  Section 1R15:  Operability Evaluations  PROCEDURE NUMBER TITLE REVISION EN-OP-104 Operability Determination Process 4 EN-DC-115 EC No. 20228 0  CALCULATION NUMBER TITLE REVISION PDS0170B SSW Basin "A" Relief Valve 2  DRAWING NUMBER TITLE REVISION FSK-M-KC187-01C1-Y Design Change Drawing SSW Basin "A" and "B" 8  Design Change Drawing Reinforced Concrete Distribution Support System Tower Elevation 157'-8" 8  OTHER NUMBER TITLE REVISION / DATE 2007-029 LBDCR Initiation  Grand Gulf Nuclear Station, Unity 1 - Conforming License Amendment to Incorporate the Mitigation Strategies Required by Section B.5.b of the Commission Order EA - 02 - 026 July 18, 2007 GNRO-2007/00037 Supplementary Response Regarding Implementation Details for the Phase 2 and 3 Mitigation Strategies Grand Gulf Nuclear Station June 7, 2007 NEI 06-12 B.5.b Phase 2 & 3 Submittal Guideline Rev 2 December 2006 7-15 GG FSAR Rev 59 9.5-3 GG UFSAR  Attachment 9.2 Immediate Determination for Degraded of Nonconforming Conditions CR-GGN-2011-01512 
  A-12    Attachment OTHER NUMBER TITLE REVISION / DATE Attachment 9.5 Operability Evaluation CR-GGN-2011-00155  NUS Switch Status  CONDITION REPORT  CR-GGN-2011-01173 CR-GGN-2011-00765 CR-GGN-2011-00155 CR-GGN-2011-00766 CR-GGN-2011-00799 CR-GGN-2011-01512 CR-GGN-2009-06838 CR-GGN-2011-01349 CR-GGN-2011-04701 CR-GGN-2011-00369 CR-GGN-2011-00643 CR-GGN-2011-00647 CR-GGN-2011-00665 CR-GGN-2011-00666 CR-GGN-2011-00667 CR-GGN-2011-00668 CR-GGN-2011-00669 CR-GGN-2011-00670 CR-GGN-2011-00671    Section 1R18:  Plant Modifications  PROCEDURE NUMBER TITLE REVISION EN-DC-136 Temporary Modifications 5 EN-LI-102 Corrective Action Process 16  DRAWING NUMBER TITLE REVISION E-1187-007 E31 Leak Detection System RWCU Flow Circuit Computer Input 7 E1165014 Schematic Design Rod Control and Information System Rod Position Information and SCRAM Time Test 13 E1173028 Schematic Design Reactor Protection System Testability 6 M1051A Main and Reheat System 33  OTHER NUMBER TITLE  06-OP-1000-D-0001 Log Data 
  A-13    Attachment OTHER NUMBER TITLE  CR-GGN-2009-02198 CA 26 CR Periodic Review (initial at 6 months/follow by annual) and/or Long Tem CA Classification Form  CONDITION REPORT  CR-GGN-2009-02198 CR-GGN-2010-04451 CR-GGN-2011-01231  WORK ORDER  WO00238932 WO00238928 WO00193921 WO00193920 WO002239736-01 WO002239736-02 WO002239736-03    ENGINEERING CHANGE  EC22768 EC22625 EC22635  Section 1R19:  Postmaintenance Testing  PROCEDURE NUMBER TITLE REVISION / DATE 06-OP-1E12-Q-0005 LPCI/RHR Subsystem A MOV Functional Test 112 06-OP-1E12-Q-0023 LPCI/RHR Subsystem A Quarterly Functional Test 121 06-0P-1E12-0006 LPCI/RHR System B MOV Functional Test 111 06-OP-1P41-Q-0004 Standby Service Water Loop A Valve AND Pump Operability Test 119 04-1-03-P75-1 Div 1 Diesel Generator Unexcited Run 7 06-OP-1P75-M-001 Data Sheet III Standby Diesel Generator 11 Functional Test February 12, 2011 07-S-12-40 General Cleaning and Inspection of Rotating Electrical Equipment  2 07-S-12-146 General Maintenance Instruction Motor Off Line Diagnostic 1 
  A-14    Attachment PROCEDURE NUMBER TITLE REVISION / DATE Data Acquisition 07-S-12-55 Insulation Resistance Testing 10 06-IC-1E22-Q-0004 HPCS System Flow Rate - Low (Bypass) Functional Test 104  OTHER NUMBER TITLE DATE  RPS Motor GEN B - MCE Stator February 2, 2011  HPCS Min Flow Valve Position  March 18, 2011  DRAWING NUMBER TITLE DATE BRKR No. 52-142229 IC71SOOIOB  BRKR No. 52-142229 IC7IS003B (Local C71-S003B)  BRKR No. 52-142229 IC7IS003D (Local C71-S003D)  Timeline for Events leading to NRC Notification Call on HPCS March 18, 2011  CONDITION REPORT  CR-GGN-2011-00945    WORK ORDER  WO52311451 WO52311569 WO52285575 WO00251847 WO52224645 WO52223715 WO00262318 WO00259110-01 WO00259110-03 WO00237650-01 WO00237650-04 WO00237650-05 WO00237650-06 WO52304041 WO00270205-01 
  A-15    Attachment WO00270205-02    Section 1R22:  Surveillance Testing  PROCEDURE NUMBER TITLE REVISION 06-CH-1B21-O-0002 Reactor Coolant Routine Chemistry-Sample February 23, 2011  106  06-CH-1B21-O-0002 Reactor Coolant Routine Chemistry-Sample February 18, 2011  106  06-CH-1B21-O-0002 Plant Operations Manual-Reactor Coolant Routine Chemistry 106 06-CH-1B21-W-0008 Reactor Coolant Dose Equivalent Iodine 104 06-OP-1C61-R-0002 Functional Checks with E51 Valves 109 06-OP-1P75-M-0001 Standby Diesel Generator Functional Test 132 06-IC-1D17-R-0010 Fuel Handling Area Ventilation Exhaust High High Radiation Electronics Time Response Test 102 04-1-01-P81-1 High Pressure Core Spray Diesel Generator 67 06-OP-1P81-M-0002 HPCS Diesel Generator 13 Functional Test 123 EN-OP-109 Conduct of Operations  2  OTHER NUMBER TITLE DATE  Drywell Unidentified Leakage Rate vs. "A" Recirc Seal Delta T June 2010- January 2011  CONDITION REPORT  CR-GGN-2011-01932 CR-GGN-2011-01868  WORK ORDER  WO52271012 WO52289870 WO52288401 WO52261837 WO52307262 WO00270146-01 
  A-16    Attachment  Section 1EP6:  Drill Evaluation  OTHER  NUMBER  TITLE    DATE    Emergency Facility Log  March 3, 2011    Repair and Corrective Action Table  March 3, 2011 Emergency Notification Form 1-7 for EP Drill  March 3, 2011 GGNS 2011 1st  Quarter ERO Training Drill  CONDITION REPORT  CR-GGN-2011-01481 CR-GGN-2011-01486 CR-GGN-2011-01495 CR-GGN-2011-01499 CR-GGN-2011-01510 CR-GGN-2011-01519 CR-GGN-2011-01520 CR-GGN-2011-01522    Section 2RS01:  Radiological Hazard Assessment and Exposure Controls  PROCEDURES  NUMBER TITLE REVISION    EN-RP-100 Radiation Worker Expectations 6 EN-RP-101 Access Control for Radiologically Controlled Areas 5 EN-RP-102 Radiological Control 2 EN-RP-106 Radiological Survey Documentation 2 01-S-08-1 Administration of the GGNS Radiation Protection Program 105 01-S-08-6 Radioactive Source Control 113 08-S-02-50 Radiological Surveys and Surveillances 116  AUDITS, SELF-ASSESSMENTS, AND SURVEILLANCES  NUMBER TITLE DATE  LO-GLO-2010-93 Pre-NRC Rad Hazard Assessment and Exposure Controls Assessment December 16, 2010  CONDITION REPORTS  CR-GGN-2011-00183 CR-GGN-2011-00551 CR-GGN-2011-00655 CR-GGN-2011-00926 CR-GGN-2011-00740     
  A-17    Attachment RADIOLOGICAL SURVEY  NUMBER TITLE DATE  GG-1102-0146 Routine Daily Surveys February 15, 2011 GG-1012-0083 208 CTMT Entire Elevation December 7, 2010 GG-1102-0152 208 CTMT Entire Elevation February 15, 2011 GG-1012-0118 119 AB RHR A Room December 9, 2010 GG-1012-0086 119 AB RHR A Room February 7, 2011 GG-1011-0254 119 AB RHR B Room November 30, 2010 GG-1101-0156 119 AB RHR B Room January 16, 2011 GG-1011-0064 93 Aux RHR C & ADHR Hx Rooms November 6, 2010 GG-1102-0044 93 Aux RHR C & ADHR Hx Rooms February 3, 2011 GG-1011-0018 119 Aux Piping Penetration & Valve Room November 2, 2010 GG-1102-0041 119 Aux Piping Penetration & Valve Room February 3, 2011 GG-1011-0063 93 Aux HPCS Pump Room November 6, 2010 GG-1102-0042 93 Aux HPCS Pump Room February 3, 2011  RADIATION WORK PERMITS  NUMBER TITLE  20101005 Tours and Inspections into all areas      20111054 Locked High Radiation Area Entries for Plant/System Investigations, Valve Manipulations, Tagouts, and Misc. Activities  20111058 Maintenance in HRA /HCA & Above  Section 2RS02:  Occupational ALARA Planning and Controls  PROCEDURES  NUMBER TITLE REVISION    EN-RP-105 Radiological Work Permits 9 EN-RP-110 ALARA Program 7  AUDITS, SELF-ASSESSMENTS, AND SURVEILLANCES  NUMBER TITLE DATE  LO # LO-GLO-2010-00094  Pre-NRC Inspection for ALARA Planning and Controls-Assessment  November 9, 2010 CONDITION REPORTS 
  A-18    Attachment CR-GGN-2011-00425 CR-GGN-2011-00425  CR-GGN-2010-06335  RADIATION WORK PERMIT PACKAGES  NUMBER TITLE  2010-1402 Refuel Floor High Water Activities  2010-1403 Reactor Disassemble/Reassemble  2010-1508 Under Vessel Activities  2010-1530 B Recirc Pump Replacement  2010-1534 B21F011B Stem Replacement  Section 4OA1:  Performance Indicator Verification  PROCEDURE NUMBER TITLE REVISION EN-LI-114 1st Quarter 2010 Unplanned Scrams per 7,000 Critical Hours 4 EN-LI-114 2nd Quarter 2010 Unplanned Scrams per 7,000 Critical Hours 4 EN-LI-114 3rd  Quarter 2010 Unplanned Scrams per 7,000 Critical Hours 4 EN-LI-114 4th Quarter 2010 Unplanned Scrams per 7,000 Critical Hours 4 EN-LI-114 1st Quarter 2010 Unplanned Scrams with Complications 4 EN-LI-114 2nd  Quarter 2010 Unplanned Scrams with Complications 4 EN-LI-114 3rd Quarter 2010 Unplanned Scrams with Complications 4 EN-LI-114 4th Quarter 2010 Unplanned Scrams with Complications 4 EN-LI-114 1st Quarter 2010 Unplanned Power Changes per 7,000 Critical Hours 4 EN-LI-114 2nd Quarter 2010 Unplanned Power Changes per 7,000 Critical Hours 4 EN-LI-114 3rd Quarter 2010 Unplanned Power Changes per 7,000 Critical Hours 4 EN-LI-114 4th Quarter 2010 Unplanned Power Changes per 7,000 Critical Hours 4 
  A-19    Attachment OTHER NUMBER TITLE  January 2010 Core Thermal Power  February 2010 Core Thermal Power  March 2010 Core Thermal Power  April 2010 Core Thermal Power  May 2010 Core Thermal Power  June 2010 Core Thermal Power  July 2010 Core Thermal Power  August 2010 Core Thermal Power  September 2010 Core Thermal Power  October 2010 Core Thermal Power  November 2010 Core Thermal Power  December 2010 Core Thermal Power  Section 4OA2:  Identification and Resolution of Problems  OTHER NUMBER TITLE DATE  GGNS Position on Riley Temperature Switch Replacement  Maintenance Rule Program Functional Failures-Riley Temperature Switches  NUS Switch Status February 2, 2011  Riley History Discussion by Lee Eaton  Riley History Presentation to 2009 PInR  CONDITION REPORT  CR-GGN-2009-05879       
  A-20    Attachment  Section 4OA3:  Event Follow-Up  PROCEDURE NUMBER TITLE REVISION EN-DC-167 Classification of Structures, Systems, and Components 3 EN-HU-103 Human Performance Error Reviews for CR-GGN-2010-7877 4 EN-DC-115 Engineering Change Process 11  DRAWINGS NUMBER TITLE REVISION M-1127A Piping and Instrumentation Diagram Noblechem Monitoring System 0 M-1081B Control Rod Drive Hydraulic System 28 M-1078A Reactor Recirculation System Unit 1 33 M-1079 Reactor Water Clean-up System Unit 1 46 M-1069A Process Sampling System Unit 1 24  OTHER NUMBER TITLE DATE  Root Cause Evaluation Report-Control Room Air Conditioner B Trip (Event Date 10-14-2010) October 16, 2010 GNRO-2010/00077 LER 2010-002-00Control Room Air Conditioning December 13, 2010  Root Cause Evaluation Report Mitigation Monitor Durability Monitor Pump Failure  November 8, 2010  MMS Skid Piping/Component Design Basis  Compliance with NRC Regulatory Guide 1.26  CONDITION REPORT  CR-GGN-2010-07315 CR-GGN-2010-08580 CR-GGN-2010-07852  ENGINEERING CHANGE 
  A-21    Attachment EC13135 EC13132 EC13138  Section 4OA5  Temporary Instruction 2515/179  PROCEDURES  NUMBER TITLE REVISION    EN-RP-143 Source Control 7      MISCELLANEOUS DOCUMENTS  TITLE  DATE    National Source Tracking System Annual Inventory Reconciliation Report 2010 National Source Tracking System Annual Inventory Reconciliation Report 2011  Section 4OA7:  Licensee-Identified Violations  CONDITION REPORT  CR-GGN-2011-00851 


Entergy Operations, Inc.                      -2-
of this inspection report, with the basis for your disagreement, to the Regional Administrator,
Region IV, and the NRC Resident Inspector at the facility.
In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, its
enclosures, and your response, if you choose to provide one, will be made available
electronically for public inspection in the NRC Public Document Room or from the NRC's
document system (ADAMS), accessible from the NRC Web site at http://www.nrc.gov/reading-
rm/adams.html. To the extent possible, your response should not include any personal privacy
or proprietary, information so that it can be made available to the Public without redaction.
                                                Sincerely,
                                                /RA/
                                                Vincent Gaddy, Chief
                                                Project Branch C
                                                Division of Reactor Projects
Docket: 50-416
License: NPF-29
Enclosed: NRC Inspection Report 05000416/2011002
w/Attachment: Supplemental Information
Distribution via ListServe
Entergy Operations, Inc.                    -3-
Electronic distribution by RIV:
Regional Administrator (Elmo.Collins@nrc.gov)
Deputy Regional Administrator (Art.Howell@nrc.gov)
DRP Director (Kriss.Kennedy@nrc.gov)
DRP Deputy Director (Troy.Pruett@nrc.gov)
DRS Director (Anton.Vegel@nrc.gov)
Senior Resident Inspector (Rich.Smith@nrc.gov)
Branch Chief, DRP/C (Vincent.Gaddy@nrc.gov)
Senior Project Engineer, DRP/C (Bob.Hagar@nrc.gov)
Project Engineer, DRP/C (Rayomand.Kumana@nrc.gov)
GG Administrative Assistant (Alley.Farrell@nrc.gov)
Public Affairs Officer (Victor.Dricks@nrc.gov)
Public Affairs Officer (Lara.Uselding@nrc.gov)
Project Manager (Alan.Wang@nrc.gov)
Branch Chief, DRS/TSB (Michael.Hay@nrc.gov)
RITS Coordinator (Marisa.Herrera@nrc.gov)
Regional Counsel (Karla.Fuller@nrc.gov)
Congressional Affairs Officer (Jenny.Weil@nrc.gov)
RIV OEDO/ETA (Stephanie Bush-Goddard@nrc.gov)
OEMail Resource
ROP Reports
File located: R:\_REACTORS\_GG\GG 2011002 RP-RLS-vgg.docx
SUNSI Rev Compl.  Yes  No ADAMS                    Yes  No    Reviewer Initials  VGG
Publicly Avail            Yes  No Sensitive        Yes  No    Sens. Type Initials VGG
SRI:DRP/PBC                              SPE:DRP/PBC    C:DRS/EB1        C:DRS/EB2
RLSmith                                  BHagar          TRFarnholtz      NFOKeefe
/RA/RCHagar for                          /RA/            /RA/              /RA/
5/4/2011                                  5/4/2011        4/21/2011        4/15/2011
C:DRS/OB                C:TSS            C:DRS/PSB1      C:DRS/PSB2        C:ACES/SAC
MHaire                  MHay              MPShannon      GEWerner          NTaylor
/RA/                    /RA/              /RA/            /RA/              /RA/
4/15/2011              4/18/2011          4/18/2011      4/15/2011          4/18/2011
C:DRP/C
VGaddy
/RA/
5/10/11
OFFICIAL RECORD COPY                                    T=Telephone      E=E-mail      F=Fax
                  U.S. NUCLEAR REGULATORY COMMISSION
                                    REGION IV
Docket:      05000416
License:    NPF-29
Report:      05000416/2011002
Licensee:    Entergy Operations, Inc.
Facility:    Grand Gulf Nuclear Station
Location:    7003 Baldhill Road
            Port Gibson, MS 39150
Dates:      January 21, 2011, through March 27, 2011
Inspectors:  R. Smith, Senior Resident Inspector
            M. Baquera, Resident Inspector, Palo Verde
            A. Fairbanks, Reactor Inspector
            C. Graves, Health Physicist
            L. Ricketson, P.E., Senior Health Physicist
            E. Uribe, Reactor Inspector
Approved By: Vincent Gaddy, Chief, Project Branch C
            Division of Reactor Projects
                                    -1-                  Enclosure
                                      SUMMARY OF FINDINGS
IR 05000416/2011002; 1/1/2011 - 3/27/2011; Grand Gulf Nuclear Station, Integrated Resident
and Regional Report; Fire Protection, Maintenance Effectiveness, Radiological Hazard
Assessment and Exposure Controls, and Event Follow-Up.
The report covered a 3-month period of inspection by resident inspectors and an announced
baseline inspection by region-based inspectors. Five Green noncited violations of significance
were identified and one Green finding of significance was identified. The significance of most
findings is indicated by their color (Green, White, Yellow, or Red) using Inspection Manual
Chapter 0609, Significance Determination Process. The cross-cutting aspect is determined
using Inspection Manual Chapter 0310, Components Within the Cross Cutting Areas. Findings
for which the significance determination process does not apply may be Green or be assigned a
severity level after NRC management review. The NRC's program for overseeing the safe
operation of commercial nuclear power reactors is described in NUREG-1649, Reactor
Oversight Process, Revision 4, dated December 2006.
A.      NRC-Identified Findings and Self-Revealing Findings
        Cornerstone: Mitigating Systems
        *        SLIV. Inspectors identified a noncited violation of 10 CFR 50.71(e)(4), which
                requires the final safety analysis report be updated, at intervals not exceeding 24
                months, to reflect changes made in the facility or procedures described in the
                final safety analysis report. Licensee personnel failed to update the original
                revision of the final safety analysis report to reflect the actual number of low
                pressure coolant injection loops available for automatic initiation during shutdown
                cooling operations in Mode 3. The licensee plans to update the final safety
                analysis report at the next scheduled revision. This finding was entered into the
                licensees corrective action program as condition report CR-GGN-2011-01631.
                The failure of licensing personnel to update the final safety analysis report to
                reflect the available low pressure coolant injection loops for automatic initiation
                during shutdown cooling operations in Mode 3 was a performance deficiency.
                This finding was evaluated using traditional enforcement because it had the
                potential for impacting the NRCs ability to perform its regulatory function. The
                inspectors used the NRC Enforcement Policy, dated September 30, 2010, to
                evaluate the significance of this violation. Consistent with the NRC Enforcement
                Policy, this finding was determined to be a Severity Level IV noncited violation.
        *      Green. The inspectors identified a noncited violation of 10 CFR Part 50.65(a)(2)
                for the licensees failure to demonstrate that the performance of the train B
                control room air conditioner was being effectively controlled through the
                performance of appropriate preventive maintenance. Engineering did not
                properly evaluate maintenance rule functional failures resulting in the system
                remaining in an a(2) status instead of an a(1) status. As corrective action, the
                                                -2-                                  Enclosure
  train B control room air conditioner was moved into an a(1) status. The licensee
  entered this issue into their corrective action program as Condition Report
  CR-GGN-2011-01623.
  The finding was more than minor because it was associated with the equipment
  performance attribute of the Mitigating Systems Cornerstone and adversely
  affected the cornerstone objective to ensure the availability, reliability, and
  capability of systems that respond to initiating events to prevent undesirable
  consequences. Inspectors performed a Phase 1 screening, in accordance with
  Inspection Manual Chapter 0609, Attachment 4, Phase 1 - Initial Screening and
  Characterization of Findings, and determined that the finding was of very low
  safety significance (Green) because the maintenance rule aspect of the finding
  did not cause an actual loss of safety function of the system nor did it cause a
  component to be inoperable. As corrective action, the train B control room air
  conditioner was moved into an (a)(1) status. This finding had a crosscutting
  aspect in the area of human performance associated with the decision making
  component because licensee personnel failed to make appropriate safety-
  significant or risk-significant decisions to address the multiple failures of the train
  B control room air conditioner compressor. [H.1(a)] (Section 1R12.b.2)
* Green. The inspectors reviewed a self-revealing noncited violation of 10 CFR
  Part 50, Appendix B, Criterion XVI, Corrective Action, after the licensee failed to
  determine the cause and prevent recurrence of a significant condition adverse to
  quality associated with the train B control room air conditioner compressor
  tripping due to low oil pressure. Specifically, on December 13, 2010, the train B
  control room air conditioner compressor tripped on low oil pressure after the
  licensee had performed a root cause analysis to identify the cause and prevent
  recurrence of a similar compressor trip on October 14, 2010. As immediate
  corrective action, the licensee installed an inline suction filter. No additional
  failures have occurred since its installation. The finding was entered into the
  licensees corrective action program as Condition Report CR-GGN-2010-07315.
  This finding was more than minor because it was associated with the equipment
  performance attribute of the Mitigating Systems Cornerstone and adversely
  affected the cornerstone objective to ensure the availability, reliability, and
  capability of systems that respond to initiating events to prevent undesirable
  consequences. Using Inspection Manual Chapter 0609, "Significance
  Determination Process," Phase 1 worksheets, the inspectors determined that a
  Phase 2 analysis was required because the finding represented a loss of system
  safety function. The plant-specific risk informed notebook does not include the
  evaluation of risk caused by the loss of cooling to the main control room.
  Therefore, the senior reactor analyst conducted a Phase 3 analysis. Based on
  the bounding analysis, the analyst determined that the change in core damage
  frequency result was 5.9 x 10-7. This noncited violation was therefore determined
  to be of very low safety significance (Green). This finding had a crosscutting
  aspect in the area of problem identification and resolution associated with the
  corrective action program component because licensee personnel failed to
                                -3-                                  Enclosure
      thoroughly evaluate the multiple failures of the train B control room air conditioner
      compressor. [P.1(c)] (Section 4OA3.1.b)
Cornerstone: Barrier Integrity
*    Green. The inspectors identified a noncited violation of Facility Operating License
      Condition 2.C(41), involving the failure to ensure that transient combustible were
      not stored in the fire exclusion zone near the independent spent fuel storage
      installation. The inspectors performed a quarterly fire protection inspection of
      independent spent fuel storage installation and identified a large air conditioner
      with combustible material covering it located in the fire exclusion zone that was
      within 60 feet of the dry fuel storage pad. The inspectors determined through
      interviews that the material had been placed there the previous day by the
      maintenance department. As immediate corrective action the licensee removed
      the combustible material from the area. The finding was entered into the
      licensees corrective action program as Condition Report CR-GGN-2011-00455.
      This finding was more than minor because it was associated human performance
      attribute of the Barrier Integrity Cornerstone to provide reasonable assurance
      that physical design barriers protect the public from radionuclide releases caused
      by accidents or events. Using Manual Chapter 0609, Appendix F, Fire
      Protection Significance Determination Process, the inspectors determined that
      the finding impacted the fire prevention and administrative controls category.
      The inspectors assigned a low degradation rating due to the fact that the amount
      of combustible material in the area was minimal. The inspectors concluded that
      the finding was of very low safety significance (Green) due to the fact there were
      no fire ignition sources in the area. The cause of this finding has a crosscutting
      aspect in the area of human performance associated with the work practices
      component because the licensee failed to effectively communicate expectations
      regarding storage of combustible material near the dry fuel storage pad. [H.4(b)]
      (Section 1R05.1.b)
*    Green. The inspectors reviewed a self-revealing, Green finding of EN-DC-115,
      Engineering Change Process, involving the failure to maintain adequate design
      control measures associated with the installation of the mitigation monitoring
      system. On November 8, 2010, a reactor coolant pressure boundary failure
      occurred at the skid mounted Online Noble Chemical - Mitigation Monitoring
      System pump inside primary containment. The positive displacement sample
      pump ejected the pump piston from the housing, resulting in an approximate
      7 gpm leak of reactor coolant. The steam leak resulted in a reactor recirculation
      system flow control valve lockup (due to hydraulic power unit motor failure) and
      approximately 15,000 square feet of contaminated area in the primary
      containment structure. The licensee failed to ensure proper validation testing for
      the pump prior to installation. Specifically, the licensee did not ensure that the
      pump could withstand the operating pressures and temperatures of the system in
                                    -4-                                  Enclosure
          which it was installed. The licensee removed the mitigation monitoring system
          from service and isolated the skid from the reactor water cleanup system. This
          finding was entered into the licensees corrective action program as Condition
          Report CR-GGN-2010-07852.
          The finding is more than minor because it affects the design control attribute of
          the Barrier Integrity Cornerstone to provide reasonable assurance that physical
          design barriers protect the public from radionuclide releases caused by accidents
          or events. Therefore, using inspection Manual Chapter 0609, "Significance
          Determination Process," Phase 1 Worksheet for LOCA initiators, the inspectors
          concluded that the finding was of very low safety significance (Green) because
          the failure of the mitigation monitoring system would not have exceeded technical
          specifications limits for identified leakage in the reactor coolant system. This
          finding has a crosscutting aspect in the work practices component of the human
          performance area; because the licensee failed to adequately oversee the design
          of the mitigation monitoring system such that nuclear safety is supported. [H.4(c)]
          (Section 4OA3.2.b)
  Cornerstone: Occupational Radiation Safety
  *      Green. The inspectors identified a noncited violation of Technical Specification
          5.7.2, resulting from the licensees failure to use a qualified radiation protection
          technician to provide direct continuous coverage of work in a locked high
          radiation area. The finding was placed into the corrective action program as
          Condition Report CR-GGN-2011-01045, and corrective action was being
          evaluated.
          The failure to use a qualified radiation protection technician to provide direct
          continuous coverage of work in a locked high radiation area is a performance
          deficiency. The finding was more than minor because it was associated with the
          Occupational Radiation Safety Cornerstone attribute (exposure control) of
          program and process and affected the cornerstone objective, in that, the failure
          to use qualified radiation protection technicians to provide job coverage in a high
          radiation area with dose rates in excess of 1000 mrem/hr had the potential to
          increase personnel dose. Using the Occupational Radiation Safety Significance
          Determination Process, the inspectors determined the finding to have very low
          safety significance because: (1) it was not associated with ALARA planning or
          work controls, (2) there was no overexposure, (3) there was no substantial
          potential for an overexposure, and (4) the ability to assess dose was not
          compromised. (Section 2RS01.b)
B. Licensee-Identified Violations
  Violations of very low safety significance, which were identified by the licensee, have
  been reviewed by the inspectors. Corrective actions taken or planned by the licensee
  have been entered into the licensees corrective action program. These violations and
  corrective action tracking numbers (condition report numbers) are listed in
  Section 4OA7.
                                        -5-                                    Enclosure
                                        REPORT DETAILS
Summary of Plant Status
Grand Gulf Nuclear Station began the inspection period at full rated thermal power. On January
9, 2011, operators reduced power to 68 percent for a planned control rod sequence exchange
and isolation of the moisture separator reheaters (MSRs) second stage steam to both the A
and B MSRs due to tube leaks in the A MSR. The plant was returned to 96 percent power on
January 10, 2011, which was maximum power level allowed with MSR second stage steam
isolated. On February 18, 2011, operators reduced power to 77 percent for monthly control rod
testing, turbine testing, and to remove B heater drain pump from service in an attempt to repair
a steam leak on the heater drain pump B discharge flange. The plant was returned to 96
percent power on February 19, 2011. On March 11, 2011, operators reduced power to 84
percent power for a planned control rod testing and to remove B heater drain pump from
service in another attempt to repair a steam leak on the heater drain pump B discharge flange.
The plant was returned to 96 percent power on March 12, 2011. On March 23, 2011, operators
reduced power to 93 percent power to remove the B heater drain pump from service again in
another attempt to repair a steam leak on the heater drain pump B pump discharge flange.
The plant was returned to 96 percent power on March 12, 2011. The plant remained at 96
percent power for the remainder of the inspection period.
1.      REACTOR SAFETY
        Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity, and
        Emergency Preparedness
1R01 Adverse Weather Protection (71111.01)
.1      Readiness for Seasonal Extreme Weather Conditions
  a.  Inspection Scope
        The inspectors performed a review of the adverse weather procedures for seasonal
        extreme low temperatures. The inspectors verified that weather-related equipment
        deficiencies identified during the previous year were corrected prior to the onset of
        seasonal extremes, and evaluated the implementation of the adverse weather
        preparation procedures and compensatory measures for the affected conditions before
        the onset of, and during, the adverse weather conditions.
        During the inspection, the inspectors focused on plant-specific design features and the
        procedures used by plant personnel to mitigate or respond to adverse weather
        conditions. Additionally, the inspectors reviewed the updated final safety analysis report
        and performance requirements for systems selected for inspection and verified that
        operator actions were appropriate as specified by plant-specific procedures. Specific
        documents reviewed during this inspection are listed in the attachment. The inspectors
        also reviewed corrective action program items to verify that plant personnel were
        identifying adverse weather issues at an appropriate threshold and entering them into
                                            -6-                                  Enclosure
      their corrective action program in accordance with station corrective action procedures.
      The inspectors reviews focused specifically on the following plant systems:
      *      Standby service water
      *      Emergency diesel generators
      *      Plant service water
      *      Fire water pumps and tanks
      These activities constitute completion of one readiness for seasonal adverse weather
      sample as defined in Inspection Procedure 71111.01-05.
  b. Findings
      No findings were identified.
.2    Readiness for Impending Adverse Weather Conditions
  a. Inspection Scope
      Since extreme cold conditions and icing were forecast in the vicinity of the facility for
      January 9, 2011, the inspectors reviewed overall preparations/protection for the
      expected weather conditions. On January 7, 2011, the inspectors inspected the standby
      service water towers because their safety-related functions could be affected as a result
      of the extreme cold and icing conditions forecast for the facility. The inspectors observed
      space heater operation and weatherized enclosures to ensure operability of affected
      systems. The inspectors reviewed licensee procedures and discussed potential
      compensatory measures with control room personnel. The inspectors focused on plant
      managements actions for implementing the stations procedures for ensuring adequate
      personnel for safe plant operation and emergency response would be available.
      Specific documents reviewed during this inspection are listed in the attachment.
      These activities constitute completion of one readiness for impending adverse weather
      condition sample as defined in Inspection Procedure 71111.01-05.
  b. Findings
      No findings were identified.
1R04 Equipment Alignments (71111.04)
.1    Partial Walkdown
  a. Inspection Scope
      The inspectors performed partial system walkdowns of the following risk-significant
      systems:
      *      Division II standby service water system during Division I maintenance outage
                                          -7-                                  Enclosure
    *      Residual heat removal system B during residual heat removal system A
            maintenance outage
    *      Residual heat removal system C during residual heat removal system A
            maintenance outage
    *      Division II standby diesel generator system during Division I maintenance outage
    *      Standby liquid control system A during standby liquid control system B
            maintenance outage
    The inspectors selected these systems based on their risk significance relative to the
    reactor safety cornerstones at the time they were inspected. The inspectors attempted
    to identify any discrepancies that could affect the function of the system, and, therefore,
    potentially increase risk. The inspectors reviewed applicable operating procedures,
    system diagrams, UFSAR, technical specification requirements, administrative technical
    specifications, outstanding work orders, condition reports, and the impact of ongoing
    work activities on redundant trains of equipment in order to identify conditions that could
    have rendered the systems incapable of performing their intended functions. The
    inspectors also inspected accessible portions of the systems to verify system
    components and support equipment were aligned correctly and operable. The
    inspectors examined the material condition of the components and observed operating
    parameters of equipment to verify that there were no obvious deficiencies. The
    inspectors also verified that the licensee had properly identified and resolved equipment
    alignment problems that could cause initiating events or impact the capability of
    mitigating systems or barriers and entered them into the corrective action program with
    the appropriate significance characterization. Specific documents reviewed during this
    inspection are listed in the attachment.
    These activities constitute completion of five partial system walkdown samples as
    defined in Inspection Procedure 71111.04-05.
  b. Findings
    No findings were identified.
1R05 Fire Protection (71111.05)
    Quarterly Fire Inspection Tours
  a. Inspection Scope
    The inspectors conducted fire protection walkdowns that were focused on availability,
    accessibility, and the condition of firefighting equipment in the following risk-significant
    plant areas:
    *      Division II diesel generator room (1D303)
                                          -8-                                  Enclosure
  *      Residual heat removal pump and heat exchanger rooms A (1A102 and 1A103)
  *      Residual heat removal pump and heat exchanger rooms B (1A105 and 1A106)
  *      Reactor Core Isolation Pump Room (1A104)
  *      Dry fuel storage pad area (Area 59 the Yard)
  The inspectors reviewed areas to assess if licensee personnel had implemented a fire
  protection program that adequately controlled combustibles and ignition sources within
  the plant; effectively maintained fire detection and suppression capability; maintained
  passive fire protection features in good material condition; and had implemented
  adequate compensatory measures for out of service, degraded or inoperable fire
  protection equipment, systems, or features, in accordance with the licensees fire plan.
  The inspectors selected fire areas based on their overall contribution to internal fire risk
  as documented in the plants Individual Plant Examination of External Events with later
  additional insights, their potential to affect equipment that could initiate or mitigate a
  plant transient, or their impact on the plants ability to respond to a security event. Using
  the documents listed in the attachment, the inspectors verified that fire hoses and
  extinguishers were in their designated locations and available for immediate use; that
  fire detectors and sprinklers were unobstructed; that transient material loading was
  within the analyzed limits; and fire doors, dampers, and penetration seals appeared to
  be in satisfactory condition. The inspectors also verified that minor issues identified
  during the inspection were entered into the licensees corrective action program.
  Specific documents reviewed during this inspection are listed in the attachment.
  These activities constitute completion of five quarterly fire-protection inspection samples
  as defined in Inspection Procedure 71111.05-05.
b. Findings
  Introduction. The inspectors identified a Green noncited violation of Facility Operating
  License Condition 2.C(41), involving the failure to ensure that transient combustible were
  not stored in the fire exclusion zone near the independent spent fuel storage installation.
  Description. On January 24, 2011, the inspectors performed a quarterly fire protection
  inspection of independent spent fuel storage installation. The inspectors identified a
  large air conditioner with combustible material covering it located in the fire exclusion
  zone that appeared to be within 60 feet of the dry fuel storage pad. The inspectors
  brought this to the attention of the work center senior reactor operator. The work center
  senior reactor operator contacted the site fire engineer, who walked down the fire
  exclusion zone and determined that the combustible material covering the air conditioner
  was within the 60 feet of the dry fuel storage pad, which is in violation of plant procedural
  requirements. The inspectors determined through interviews that the material had been
  placed there the day before by the maintenance department. The site had the air
  conditioner and the covering material removed from the fire exclusion zone to restore
  compliance.
  The licensee documented this violation in Condition Report CR-GGN-2011-00455. Its
  short-term corrective actions included removing the combustible material from the area.
                                          -9-                                  Enclosure
    Analysis. The inspectors determined that the failure to follow fire protection procedures
    developed for control of transient combustible material stored near the dry spent fuel
    storage pad was a performance deficiency. This finding was more than minor because it
    was associated human performance attribute of the Barrier Integrity Cornerstone to
    provide reasonable assurance that physical design barriers protect the public from
    radionuclide releases caused by accidents or events. Using Manual Chapter 0609,
    Appendix F, Fire Protection Significance Determination Process, the inspectors
    determined that the finding impacted the fire prevention and administrative controls
    category. The inspectors assigned a low degradation rating due to the fact that the
    amount of combustible material in the area was minimal. The inspectors concluded that
    the finding was of very low safety significance (Green) due to the fact there were no fire
    ignition sources in the area. The finding has a crosscutting aspect in the area of human
    performance associated with the work practices component because the licensee failed
    to effectively communicate expectations regarding storage of combustible material near
    the dry fuel storage pad. [H.4(b)]
    Enforcement. Grand Gulf Nuclear Station Facility Operating License Condition 2.C(41)
    states, in part, that the plant shall implement and maintain in effect all provisions of the
    Fire Protection Program as described in the UFSAR. UFSAR Section 9B,
    Administrative Controls, section 9B.6.a, governs the handling and limits the use of
    ordinary combustible materials in safety related areas. Fire area 59, defined as the yard,
    contains the fire exclusion area next to the dry fuel storage pad and prohibits the storage
    of any combustible material in this area. Contrary to this, on January 23, 2011, the
    licensee stored combustible material inside the transient combustible exclusion zone
    near the dry fuel storage pad. The licensee restored compliance by removing the
    material from the area on January 25, 2011. Because the finding was of very low safety
    significance (Green) and was documented in the licensees corrective action program as
    CR-GGN-2011-0455, this finding is being treated as a noncited violation (NCV)
    consistent with Section VI.A of the NRC Enforcement Policy:
    NCV 05000416/2011002-01; Transient Combustible Stored in the Fire Exclusion Zone
    Near the Independent Spent Fuel Storage Installation.
1R06 Flood Protection Measures (71111.06)
  a. Inspection Scope
    The inspectors reviewed the flooding analysis, and plant procedures to assess seasonal
    susceptibilities involving internal flooding; reviewed the Updated Final Safety Analysis
    Report and corrective action program to determine if licensee personnel identified and
    corrected flooding problems; inspected underground bunkers/manholes to verify the
    adequacy of sump pumps, level alarm circuits, cable splices subject to submergence,
    and drainage for bunkers/manholes; subject to flooding that contain cables whose failure
    could disable risk-significant equipment. The inspectors walked down the areas listed
    below. Specific documents reviewed during this inspection are listed in the attachment.
    *      January 11, 2011, division 1 and 2 standby service water manholes
                                            - 10 -                                Enclosure
    These activities constitute completion of one bunker/manhole sample as defined in
    Inspection Procedure 71111.06-05.
  b. Findings
    No findings were identified.
1R07 Heat Sink Performance (71111.07)
  a. Inspection Scope
    The inspectors reviewed licensee programs, verified performance against industry
    standards, and reviewed critical operating parameters and maintenance records for the
    Division 1 emergency diesel generator jacket water and lube oil heat exchangers. The
    inspectors verified that performance tests were satisfactorily conducted for heat
    exchangers/heat sinks and reviewed for problems or errors; the licensee utilized the
    periodic maintenance method outlined in EPRI Report NP 7552, Heat Exchanger
    Performance Monitoring Guidelines; the licensee properly utilized biofouling controls;
    the licensees heat exchanger inspections adequately assessed the state of cleanliness
    of their tubes; and the heat exchanger was correctly categorized under 10 CFR 50.65,
    Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power
    Plants. Specific documents reviewed during this inspection are listed in the attachment.
    These activities constitute completion of one heat sink inspection sample as defined in
    Inspection Procedure 71111.07-05.
  b. Findings
    No findings were identified.
1R11 Licensed Operator Requalification Program (71111.11)
  a. Inspection Scope
    On January 31, 2011, the inspectors observed a crew of licensed operators in the plants
    simulator to verify that operator performance was adequate, evaluators were identifying
    and documenting crew performance problems and training was being conducted in
    accordance with licensee procedures. The inspectors evaluated the following areas:
    *        Licensed operator performance
    *        Crews clarity and formality of communications
    *        Crews ability to take timely actions in the conservative direction
    *        Crews prioritization, interpretation, and verification of annunciator alarms
    *        Crews correct use and implementation of abnormal and emergency procedures
                                          - 11 -                                Enclosure
    *      Control board manipulations
    *      Oversight and direction from supervisors
    *      Crews ability to identify and implement appropriate technical specification
            actions and emergency plan actions and notifications
    The inspectors compared the crews performance in these areas to preestablished
    operator action expectations and successful critical task completion requirements.
    Specific documents reviewed during this inspection are listed in the attachment.
    These activities constitute completion of one quarterly licensed-operator requalification
    program sample as defined in Inspection Procedure 71111.11.
  b. Findings
    No findings were identified.
1R12 Maintenance Effectiveness (71111.12)
  a. Inspection Scope
    The inspectors evaluated degraded performance issues involving the following risk
    significant systems:
    *      Appendix R emergency lighting units (Z92)
    *      Control room air conditioning (Z51)
    *      Residual heat removal (E12)
    The inspectors reviewed events such as where ineffective equipment maintenance has
    resulted in valid or invalid automatic actuations of engineered safeguards systems and
    independently verified the licensee's actions to address system performance or condition
    problems in terms of the following:
    *      Implementing appropriate work practices
    *      Identifying and addressing common cause failures
    *      Scoping of systems in accordance with 10 CFR 50.65(b)
    *      Characterizing system reliability issues for performance
    *      Charging unavailability for performance
    *      Trending key parameters for condition monitoring
                                          - 12 -                              Enclosure
    *        Ensuring proper classification in accordance with 10 CFR 50.65(a)(1) or -(a)(2)
    *        Verifying appropriate performance criteria for structures, systems, and
            components classified as having an adequate demonstration of performance
            through preventive maintenance, as described in 10 CFR 50.65(a)(2), or as
            requiring the establishment of appropriate and adequate goals and corrective
            actions for systems classified as not having adequate performance, as described
            in 10 CFR 50.65(a)(1)
    The inspectors assessed performance issues with respect to the reliability, availability,
    and condition monitoring of the system. In addition, the inspectors verified maintenance
    effectiveness issues were entered into the corrective action program with the appropriate
    significance characterization. Specific documents reviewed during this inspection are
    listed in the attachment.
    These activities constitute completion of three quarterly maintenance effectiveness
    samples as defined in Inspection Procedure 71111.12-05.
b.  Findings
.1 Failure to Update Available Low Pressure Cooling Injection Loops in the Updated Final
    Safety Analysis Report
    Introduction. Inspectors identified a Severity Level IV, noncited violation for the
    licensees failure to update the final (updated) safety analysis report in accordance with
    10 CFR 50.71(e)(4). Specifically, the licensee failed to update Section 6.3, Emergency
    Core Cooling Systems, to appropriately reflect the available emergency core cooling
    equipment during shutdown cooling operations in Mode 3.
    Description. On February 28, 2011, while reviewing the updated final safety analysis
    report for a maintenance effectiveness inspection of the residual heat removal system,
    the inspectors determined that Section 6.3.1.1.1.e, Emergency Core Cooling Systems,
    states, The ECCS is designed to satisfy all criteria specified in Section 6.3 for any
    normal mode of reactor operation. Additionally, Section 6.3.1.1.2.d states, In the event
    of a break in a pipe that is part of the reactor coolant pressure boundary, no single active
    component failure in the emergency core cooling system shall prevent automatic
    initiation and successful operation of less than the following combination of emergency
    core cooling system equipment: 1) Three low pressure coolant injection loops, the low
    pressure core spray and the automatic depressurization system (i.e., high pressure core
    spray failure); 2) Two low pressure coolant injection loops, the high pressure core spray
    and the automatic depressurization system (i.e., low pressure core spray diesel
    generator failure); and 3) One low pressure coolant injection loop, the low pressure core
    spray, the high pressure core spray and automatic depressurization system (i.e., low
    pressure coolant injection diesel generator failure).
    Procedure 03-1-01-3, Plant Shutdown, Revision 118, Section 6.14 states, When
    shutdown cooling is placed in service at less than 135 psig, then the associated
    containment spray and low pressure coolant injection systems may be considered
                                          - 13 -                                Enclosure
  operable if capable of being manually realigned and not otherwise inoperable.
  Inspectors noted that because the residual heat removal system that provides shutdown
  cooling in Mode 3 is not available for automatic initiation (must be manually realigned) of
  low pressure coolant injection, in the event of a reactor coolant system pipe break, that
  the aforementioned statements in Section 6.3 did not appropriately reflect the available
  emergency core cooling equipment during shutdown cooling operations. In other words,
  the combinations of emergency core cooling equipment available for automatic initiation
  would include one less low pressure coolant injection loop.
  The licensee entered this issue into their corrective actions program as Condition Report
  CR-GGN-2011-01631. The licensee planned to take actions to update the updated final
  safety analysis report at the next scheduled revision.
  Analysis. The failure of licensing personnel to update the final safety analysis report to
  reflect the available low pressure coolant injection loops for automatic initiation during
  shutdown cooling operations in Mode 3 was a performance deficiency. This finding was
  evaluated using traditional enforcement because it had the potential for impacting the
  NRCs ability to perform its regulatory function. The inspectors used the NRC
  Enforcement Policy, dated September 30, 2010, to evaluate the significance of this
  violation. Consistent with the NRC Enforcement Policy, this finding was determined to
  be a Severity Level IV noncited violation. This finding had no crosscutting aspect as it
  was associated with a traditional enforcement violation.
  Enforcement. Title 10 CFR 50.71(e)(4) requires the final safety analysis report be
  updated, at intervals not exceeding 24 months, and states in part, the revisions must
  reflect all changes made in the facility or procedures described in the FSAR. Contrary
  to the above, licensing personnel failed to update the original revision of the final safety
  analysis report to reflect the actual number of low pressure coolant injection loops
  available for automatic initiation during shutdown cooling operations in Mode 3.
  Because the finding is of very low safety significance and has been entered into the
  corrective action program as Condition Report CR-GGN-2011-01631, this violation is
  being treated as a noncited violation consistent with the NRC Enforcement Policy:
  NCV 0500416/20011002-02, "Failure to Update Available Low Pressure Coolant
  Injection Loops in the Updated Final Safety Analysis Report."
.2 Failure to Demonstrate Maintenance Effectiveness of Train B Control Room Air
  Conditioner
  Introduction. The inspectors identified a Green noncited violation of 10 CFR Part
  50.65(a)(2) for the failure to demonstrate that the performance of the train B control
  room air conditioner was being effectively controlled through the performance of
  appropriate preventive maintenance.
  Description. On March 2, 2011, the inspectors performed a maintenance effectiveness
  inspection of the control room air conditioning system. Inspectors determined that on
  February 3, 2010, the train B control room air conditioner compressor was replaced with
  a remanufactured compressor as part of annual preventative maintenance of the
  system. On March 27, 2010, the control room air conditioner compressor tripped on low
                                        - 14 -                                Enclosure
usable oil pressure. The licensees investigation revealed that the compressor pencil
strainer was approximately fifty percent covered with unidentified contaminants. Similar
contaminants were identified on the oil sump strainer. The licensee concluded that the
compressor had been installed with contaminants inside the lower half of the
compressor, and subsequently replaced the remanufactured compressor on April 1,
2010, with a newly rebuilt compressor. System engineering did not classify this event as
a maintenance rule functional failure even though operations had declared the train
inoperable and also stated in their operability determination that it could not meet its 30
day mission time.
The train B control room air conditioner compressor subsequently either tripped or failed
to properly cool the control room, due to low usable oil pressure, on three separate
occasions (once in April, once May, and once in June). In response to the June failure,
the licensee performed extensive maintenance on the train B control room air
conditioner compressor, which included installing a five micron suction line filter in the
system. Additionally, all three events were identified as maintenance rule functional
failures attributed to foreign material fouling in the system, which would have resulted in
the performance criteria being exceeded (less than or equal to two maintenance rule
functional failure events or as a repeat functional failure). However, the sites
maintenance rule coordinator informed the inspectors that the first two events in April
and May were not counted toward the criteria because they were from the same cause
as the June event and; therefore, they would all be counted as one failure even thought
the train was returned to service each time after corrective maintenance was performed
and declared operable by operations. Additionally, on June 22, 2010, the train was
declared inoperable due to multiple Freon leaks and was classified as another
maintenance rule functional failure for the train. On August 10, 2010, the licensee
performed a Maintenance Rule (a)(1) evaluation for the subject system and, based on
the presentation to the expert panel by system engineering, the panel only considered
two events as maintenance rule functional failures. System engineering did not count
the one failure in March or consider the two failures in April or May. The expert panel
only considered the failures in June due to low oil pressure and Freon leaks. Therefore
the expert panel concluded that, although the train B control room air conditioner system
had exceeded its established performance criteria for functional failure events, a number
of effective corrective actions had been identified and implemented and additional
corrective actions were not necessary; therefore, the subject system was allowed to
retain its (a)(2) status.
The train B control room air conditioner compressor subsequently either tripped or failed
to properly cool the control room, due to low usable oil pressure, on two separate
occasions (once in September and once in October). The October trip of the subject
system compressor occurred while the train A control room air conditioner was out of
service for routine maintenance. The compressor pencil strainer and sump strainer were
again identified with contaminants on them. The licensee was required to make an
eight-hour report to the NRC and submit a licensee event report due to both trains of
control room air conditioner being inoperable. The licensees root cause analysis failed
to identify that the train B control room air conditioner performance had not been
demonstrated through the performance of appropriate preventative maintenance; nor did
the root cause identify that the licensee failed to set goals and monitor the system as
                                      - 15 -                              Enclosure
required by 10 CFR 50.65(a)(1). The train B control room air conditioner was ultimately
moved into (a)(1) status on February 4, 2011, after the subject compressor again tripped
due to low oil pressure on December 13, 2010. After this trip and upon further
evaluation, the licensee performed an additional corrective action that installed an in line
suction filter with smaller filtering diameter and larger surface area to remove foreign
material from the system. They also modified the operator rounds to obtain daily
readings of differential pressure across this new filter and through calculation,
determined a differential pressure necessary for the filter to be changed out and the unit
to be inspected for foreign materials.
The licensee entered this issue into their corrective actions program as Condition Report
CR-GGN-2011-01623. From installation of the new inline suction filter to the conclusion
of the inspection period, no additional trips of train B control room air conditioning have
occurred.
Analysis. The inspectors determined that the failure to demonstrate that the
performance of the train B control room air conditioner was being effectively controlled
through the performance of appropriate preventive maintenance was a performance
deficiency. The finding was more than minor because it was associated with the
equipment performance attribute of the Mitigating Systems Cornerstone and adversely
affected the cornerstone objective to ensure the availability, reliability, and capability of
systems that respond to initiating events to prevent undesirable consequences.
Inspectors performed a Phase 1 screening, in accordance with Inspection Manual
Chapter 0609, Attachment 4, Phase 1 - Initial Screening and Characterization of
Findings, and determined that the finding was of very low safety significance (Green)
because it did not result in a loss of system safety function since the train A control room
air conditioner remained operable. This finding had a crosscutting aspect in the area of
human performance associated with the decision making component because licensee
personnel failed to make appropriate safety-significant or risk-significant decisions to
address the multiple failures of the train B CRAC compressor. [H.1(a)]
Enforcement. Title 10 CFR 50.65(a)(2), states, in part, that monitoring as specified in
paragraph (a)(1) of this section is not required where it has been demonstrated that the
performance or condition of a structure, system, or component is being effectively
controlled through the performance of appropriate preventative maintenance, such that
the structure, system, or component remains capable of performing its intended
function. Contrary to the above, from March 2010 to February 2011, the licensee failed
to demonstrate that the performance of the train B control room air conditioning system
was effectively controlled through the performance of appropriate preventative
maintenance. This finding was entered into the licensees corrective action program as
Condition Report CR-GGN-2011-01623. Because this finding was determined to be of
very low safety significance and was entered into the licensees corrective action
program, this violation is being treated as a noncited violation consistent with the NRC
Enforcement Policy: NCV 05000285/2011002-03, Failure to Demonstrate Maintenance
Effectiveness of Train B Control Room Air Conditioner.
                                      - 16 -                                Enclosure
1R13 Maintenance Risk Assessments and Emergent Work Control (71111.13)
  a. Inspection Scope
    The inspectors reviewed licensee personnel's evaluation and management of plant risk
    for the maintenance and emergent work activities affecting risk-significant and safety-
    related equipment listed below to verify that the appropriate risk assessments were
    performed prior to removing equipment for work:
    *        On January 9, 2011, during an ice storm requiring the plant to enter a yellow risk
              condition and enter their off normal event procedure for severe weather.
    *        On February 3, 2011, during an ice storm requiring the plant to enter a yellow risk
              condition and enter their off normal event procedure for severe weather. The
              weather required the site to cancel work and monitor their safety related standby
              service water system for icing conditions.
    *        On February 9, 2011, during a winter storm, while a divisions 1 diesel generator
              and residual heat removal A were out for planned maintenance outage requiring
              the plant to enter orange risk.
    *        On February 28, 2011, during the accidental unearthing of energized plant
              service water pump cables, no consequence to the plant but resulted in work
              stoppage and evaluation of risk status for the site.
    *        On March 8-9, 2011, with an emergent issue with the division 1 diesel generator
              and a tornado watch issued for the area requiring the plant to enter yellow risk.
              The site entered their severe weather off normal procedure; this procedure
              required the site to secure from half scram surveillances.
    The inspectors selected these activities based on potential risk significance relative to
    the reactor safety cornerstones. As applicable for each activity, the inspectors verified
    that licensee personnel performed risk assessments as required by 10 CFR 50.65(a)(4)
    and that the assessments were accurate and complete. When licensee personnel
    performed emergent work, the inspectors verified that the licensee personnel promptly
    assessed and managed plant risk. The inspectors reviewed the scope of maintenance
    work, discussed the results of the assessment with the licensee's probabilistic risk
    analyst or shift technical advisor, and verified plant conditions were consistent with the
    risk assessment. The inspectors also reviewed the technical specification requirements
    and inspected portions of redundant safety systems, when applicable, to verify risk
    analysis assumptions were valid and applicable requirements were met. Specific
    documents reviewed during this inspection are listed in the attachment.
    These activities constitute completion of five emergent work control inspection samples
    as defined in Inspection Procedure 71111.13-05.
                                          - 17 -                              Enclosure
  b. Findings
    No findings were identified.
1R15 Operability Evaluations (71111.15)
  a. Inspection Scope
    The inspectors reviewed the following issues:
    *      Division 3 high pressure core spray diesel generator outside air fan temperature
            switch fluctuating
    *      Train A standby service water drift eliminator support base plate corrosion and
            missing brass bolts
    *      Train A standby service water valve P41-F299A flange degradation
    *      Residual heat removal equipment area temperature high/inoperable due to
            temperature switch
    *      Site fire truck inoperable
    *      Division 1 diesel generator auxiliary oil pump not obtaining procedural pressures
            during pre-lube prior to surveillance run
    The inspectors selected these potential operability issues based on the risk significance
    of the associated components and systems. The inspectors evaluated the technical
    adequacy of the evaluations to ensure that technical specification operability was
    properly justified and the subject component or system remained available such that no
    unrecognized increase in risk occurred. The inspectors compared the operability and
    design criteria in the appropriate sections of the technical specifications and UFSAR to
    the licensee personnels evaluations to determine whether the components or systems
    were operable. Where compensatory measures were required to maintain operability,
    the inspectors determined whether the measures in place would function as intended
    and were properly controlled. The inspectors determined, where appropriate,
    compliance with bounding limitations associated with the evaluations. Additionally, the
    inspectors also reviewed a sampling of corrective action documents to verify that the
    licensee was identifying and correcting any deficiencies associated with operability
    evaluations. Specific documents reviewed during this inspection are listed in the
    attachment.
    These activities constitute completion of six operability evaluations inspection samples
    as defined in Inspection Procedure 71111.15-04
                                        - 18 -                                Enclosure
  b. Findings
    No findings were identified.
1R18 Plant Modifications (71111.18)
  a. Inspection Scope
    To verify that the safety functions of important safety systems were not degraded, the
    inspectors reviewed the following temporary modifications:
    *      Temporary Modification for RWCU A/B Leak Detection (EC 22625 & EC 22635)
    *      Temporary Modification to install bypass signals for B first stage Pressure
            Sensor (EC22768)
    The inspectors reviewed the temporary modifications and the associated safety-
    evaluation screening against the system design bases documentation, including the
    updated final safety analysis report and the technical specifications, and verified that the
    modification did not adversely affect the system operability/availability. The inspectors
    also verified that the installation and restoration were consistent with the modification
    documents and that configuration control was adequate. Additionally, the inspectors
    verified that the temporary modification was identified on control room drawings,
    appropriate tags were placed on the affected equipment, and licensee personnel
    evaluated the combined effects on mitigating systems and the integrity of radiological
    barriers.
    These activities constitute completion of two samples for temporary plant modifications
    as defined in Inspection Procedure 71111.18-05.
  b. Findings
    No findings were identified.
1R19 Postmaintenance Testing (71111.19)
  a. Inspection Scope
    The inspectors reviewed the following postmaintenance activities to verify that
    procedures and test activities were adequate to ensure system operability and functional
    capability:
    *      For standby liquid B after a maintenance outage
    *      For reactor protection motor generator B after required maintenance
    *      For residual heat removal system A after a maintenance outage
                                          - 19 -                                Enclosure
    *        For standby service water system A after a maintenance outage
    *        For division 1 diesel generator after a maintenance outage
    *        For high pressure core spray minimum flow valve 1E22-F012 after corrective
              maintenance
    The inspectors selected these activities based upon the structure, system, or
    component's ability to affect risk. The inspectors evaluated these activities for the
    following (as applicable):
    *        The effect of testing on the plant had been adequately addressed; testing was
              adequate for the maintenance performed
    *        Acceptance criteria were clear and demonstrated operational readiness; test
              instrumentation was appropriate
    The inspectors evaluated the activities against the technical specifications, the UFSAR,
    10 CFR Part 50 requirements, licensee procedures, and various NRC generic
    communications to ensure that the test results adequately ensured that the equipment
    met the licensing basis and design requirements. In addition, the inspectors reviewed
    corrective action documents associated with postmaintenance tests to determine
    whether the licensee was identifying problems and entering them in the corrective action
    program and that the problems were being corrected commensurate with their
    importance to safety. Specific documents reviewed during this inspection are listed in
    the attachment.
    These activities constitute completion of six postmaintenance testing inspection samples
    as defined in Inspection Procedure 71111.19-05.
  b. Findings
    No findings were identified.
1R22 Surveillance Testing (71111.22)
  a. Inspection Scope
    The inspectors reviewed the UFSAR, procedure requirements, and technical
    specifications to ensure that the surveillance activities listed below demonstrated that the
    systems, structures, and/or components tested were capable of performing their
    intended safety functions. The inspectors either witnessed or reviewed test data to
    verify that the significant surveillance test attributes were adequate to address the
    following:
    *        Preconditioning
                                          - 20 -                              Enclosure
*      Evaluation of testing impact on the plant
*      Acceptance criteria
*      Test equipment
*      Procedures
*      Test data
*      Testing frequency and method demonstrated technical specification operability
*      Test equipment removal
*      Restoration of plant systems
*      Updating of performance indicator data
*      Engineering evaluations, root causes, and bases for returning tested systems,
        structures, and components not meeting the test acceptance criteria were correct
*      Reference setting data
*      Annunciators and alarms setpoints
The inspectors also verified that licensee personnel identified and implemented any
needed corrective actions associated with the surveillance testing.
*      On January 7, 2011, reactor coolant system leakage detection surveillance
*      On February 4, 2011, inservice test of residual heat removal system B quarterly
*      On February 23, 2011, reactor coolant routine chemistry surveillance
*      On March 2, 2011, fuel handling area ventilation exhaust radiation monitor time
        response test
*      On March 10, 2011, division 1 diesel generator monthly surveillance
*      On March 18, 2011, division 3 diesel generator monthly surveillance
*      On March 20-21, 2011, functional checks with reactor core isolation cooling
        valves at the remote shutdown panel
Specific documents reviewed during this inspection are listed in the attachment.
                                    - 21 -                              Enclosure
      These activities constitute completion of seven surveillance (one reactor coolant system
      leakage detection, one inservice test, and five routine tests) testing inspection samples
      as defined in Inspection Procedure 71111.22-05.
  b. Findings
      No findings were identified.
      Cornerstone: Emergency Preparedness
1EP6 Drill Evaluation (71114.06)
.1    Emergency Preparedness Drill Observation
  a. Inspection Scope
      The inspectors evaluated the conduct of a routine licensee emergency drill on March 3,
      2011, to identify any weaknesses and deficiencies in classification, notification, and
      protective action recommendation development activities. The inspectors observed
      emergency response operations in the simulator control room and emergency
      operations facility to determine whether the event classification, notifications, and
      protective action recommendations were performed in accordance with procedures. The
      inspectors also attended the licensee drill critique to compare any inspector-observed
      weakness with those identified by the licensee staff in order to evaluate the critique and
      to verify whether the licensee staff was properly identifying weaknesses and entering
      them into the corrective action program. As part of the inspection, the inspectors
      reviewed the drill package and other documents listed in the attachment.
      These activities constitute completion of one sample as defined in Inspection
      Procedure 71114.06-05.
  b. Findings
      No findings were identified.
2.    RADIATION SAFETY
      Cornerstone: Occupational and Public Radiation Safety
2RS01 Radiological Hazard Assessment and Exposure Controls (71124.01)
  a. Inspection Scope
      This area was inspected to: (1) review and assess licensees performance in assessing
      the radiological hazards in the workplace associated with licensed activities and the
      implementation of appropriate radiation monitoring and exposure control measures for
      both individual and collective exposures, (2) verify the licensee is properly identifying
      and reporting Occupational Radiation Safety Cornerstone performance indicators, and
                                          - 22 -                                Enclosure
  (3) identify those performance deficiencies that were reportable as a performance
  indicator and which may have represented a substantial potential for overexposure of
  the worker.
  The inspectors used the requirements in 10 CFR Part 20, the technical specifications,
  and the licensees procedures required by technical specifications as criteria for
  determining compliance. During the inspection, the inspectors interviewed the radiation
  protection manager, radiation protection supervisors, and radiation workers. The
  inspectors performed walkdowns of various portions of the plant, performed independent
  radiation dose rate measurements and reviewed the following items:
  *      Performance indicator events and associated documentation reported by the
          licensee in the Occupational Radiation Safety Cornerstone
  *      The hazard assessment program, including a review of the licenses evaluations
          of changes in plant operations and radiological surveys to detect dose rates,
          airborne radioactivity, and surface contamination levels
  *      Instructions and notices to workers, including labeling or marking containers of
          radioactive material, radiation work permits, actions for electronic dosimeter
          alarms, and changes to radiological conditions
  *      Programs and processes for control of sealed sources and release of potentially
          contaminated material from the radiologically controlled area, including survey
          performance, instrument sensitivity, release criteria, procedural guidance, and
          sealed source accountability
  *      Radiological hazards control and work coverage, including the adequacy of
          surveys, radiation protection job coverage, and contamination controls; the use of
          electronic dosimeters in high noise areas; dosimetry placement; airborne
          radioactivity monitoring; controls for highly activated or contaminated materials
          (non-fuel) stored within spent fuel and other storage pools; and posting and
          physical controls for high radiation areas and very high radiation areas
  *      Radiation worker and radiation protection technician performance with respect to
          radiation protection work requirements
  *      Audits, self-assessments, and corrective action documents related to radiological
          hazard assessment and exposure controls since the last inspection
  Specific documents reviewed during this inspection are listed in the attachment.
  These activities constitute completion of the one required sample as defined in
  Inspection Procedure 71124.01-05.
b. Findings
                                        - 23 -                                Enclosure
Introduction. The inspectors identified a Green, noncited violation of Technical
Specification 5.7.2, resulting from the licensees failure to use a qualified radiation
protection technician to provide direct continuous coverage of work in a locked high
radiation area.
Description. The inspectors reviewed Condition Report CR-GGN-2011-00655, which
documented the identification by Cooper Nuclear Station that a contractor seeking
employment as a radiation protection technician did not meet ANSI 18.1 requirements.
The finding, documented February 2, 2011, was discussed with Entergy sites during a
teleconference. Then, Grand Gulf Nuclear Station determined the individual had been
employed as a radiation protection technician at Grand Gulf Nuclear Station during
Refueling Outage 17, conducted in April and May 2010. In response, Grand Gulf
Nuclear Station reviewed the radiation surveys performed by the individual (from April 15
through May 13, 2010), concluded the surveys contained data comparable with that
documented in other surveys in the same areas under similar conditions, and closed the
condition report on February 8, 2011. The inspectors reviewed the radiation survey
records included in the condition report and noted something the licensee had not
addressed. On April 27, 2010, the individual had provided job coverage for work in a
locked high radiation area (an area with dose rates greater than 1000 mrem/hour).
Survey GG-1004-0660 identified the work area as the 128-foot auxiliary pipe chase,
above the reactor water cleanup pump rooms. Since the individual used by the licensee
to provide job coverage and surveillance in a locked high radiation area was not a
qualified radiation protection technician, the inspectors identified this as a performance
deficiency.
Analysis. The failure to use a qualified radiation protection technician to provide direct
continuous coverage of work in a locked high radiation area is a performance deficiency.
The finding was more than minor because it was associated with the Occupational
Radiation Safety Cornerstone attribute (exposure control) of program and process and
affected the cornerstone objective, in that, the failure to use qualified radiation protection
technicians to provide job coverage in a high radiation area with dose rates in excess of
1000 mrem/hr had the potential to increase personnel dose. Using the Occupational
Radiation Safety Significance Determination Process, the inspectors determined the
finding to have very low safety significance because: (1) it was not associated with
ALARA planning or work controls, (2) there was no overexposure, (3) there was no
substantial potential for an overexposure, and (4) the ability to assess dose was not
compromised. The inspectors identified no cross-cutting aspect associated with this
finding.
Enforcement. Technical Specification 5.7.2, controls for high radiation areas with dose
rates greater than 1000 mrem/hour, consists of all the controls for high radiation areas
(Technical Specification 5.7.1) plus it requires doors to the area remain locked except
during periods of access by personnel under an approved radiation work permit that
shall specify the dose rate levels in the immediate work areas and the maximum
allowable stay times for individuals in those areas. In lieu of the stay time specification
for the radiation work permit, direct or remote continuous surveillance may be made by
personnel qualified in radiation protection procedures to provide positive exposure
                                    - 24 -                                Enclosure
      control over the activities being performed within the area. Contrary to the above, during
      work in an area with dose rates greater than 1000 mrem/hour on April 27, 2010, in lieu of
      the stay time specification for the radiation work permit, direct or remote surveillance
      was not made by personnel qualified in radiation protection procedures to provide
      positive exposure control over the activities being performed within the area. Instead, an
      unqualified person was assigned to provide surveillance of a locked high radiation on
      April 27, 2010. The licensee initiated Condition Report CR-GGN-2011-01045 to
      document the fact that it failed to identify this performance deficiency as part of the
      review associated with the closure of Condition Report CR-GGN-2011-00655.
      Because the violation was of very low safety significance and it was entered into the
      licensees corrective action program, the violation is being treated as a noncited
      violation, consistent with the enforcement policy. NCV 05000416/2011002-04, Failure
      to Use a Qualified Radiation Protection Technician to Provide Direct Continuous
      Coverage of Work in a Locked High Radiation Area.
2RS02 Occupational ALARA Planning and Controls (71124.02)
  a.  Inspection Scope
      This area was inspected to assess performance with respect to maintaining occupational
      individual and collective radiation exposures as low as is reasonably achievable
      (ALARA). The inspectors used the requirements in 10 CFR Part 20, the technical
      specifications, and the licensees procedures required by technical specifications as
      criteria for determining compliance. During the inspection, the inspectors interviewed
      licensee personnel and reviewed the following items:
      *        Site-specific ALARA procedures and collective exposure history, including the
              current 3-year rolling average, site-specific trends in collective exposures, and
              source-term measurements
      *        ALARA work activity evaluations/postjob reviews, exposure estimates, and
              exposure mitigation requirements
      *        The methodology for estimating work activity exposures, the intended dose
              outcome, the accuracy of dose rate and man-hour estimates, and intended
              versus actual work activity doses and the reasons for any inconsistencies
      *        Records detailing the historical trends and current status of tracked plant source
              terms and contingency plans for expected changes in the source term due to
              changes in plant fuel performance issues or changes in plant primary chemistry
      *        Radiation worker and radiation protection technician performance during work
              activities in radiation areas, airborne radioactivity areas, or high radiation areas
      *        Audits, self-assessments, and corrective action documents related to ALARA
              planning and controls since the last inspection
                                            - 25 -                                Enclosure
      Specific documents reviewed during this inspection are listed in the attachment.
      These activities constitute completion of the one required sample as defined in
      Inspection Procedure 71124.02-05.
  b. Findings
      No findings were identified.
4.    OTHER ACTIVITIES
4OA1 Performance Indicator Verification (71151)
.1    Data Submission Issue
  a. Inspection Scope
      The inspectors performed a review of the performance indicator data submitted by the
      licensee for the fourth Quarter 2010 performance indicators for any obvious
      inconsistencies prior to its public release in accordance with Inspection Manual
      Chapter 0608, Performance Indicator Program.
      This review was performed as part of the inspectors normal plant status activities and,
      as such, did not constitute a separate inspection sample.
  b. Findings
      No findings were identified.
.2    Unplanned Scrams per 7000 Critical Hours (IE01)
  a. Inspection Scope
      The inspectors sampled licensee submittals for the unplanned scrams per 7000 critical
      hours performance indicator for the period from the first quarter 2010 through the fourth
      quarter 2010. To determine the accuracy of the performance indicator data reported
      during those periods, the inspectors used definitions and guidance contained in NEI
      Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 6.
      The inspectors reviewed the licensees operator narrative logs, condition reports, event
      reports, and NRC integrated inspection reports for the period of January 2010 through
      December 2010 to validate the accuracy of the submittals. The inspectors also reviewed
      the licensees condition report database to determine if any problems had been identified
      with the performance indicator data collected or transmitted for this indicator and none
      were identified. Specific documents reviewed are described in the attachment to this
      report.
      These activities constitute completion of one unplanned scrams per 7000 critical hours
      sample as defined in Inspection Procedure 71151-05.
                                          - 26 -                              Enclosure
  b. Findings
      No findings were identified.
.3    Unplanned Scrams with Complications (IE02)
  a. Inspection Scope
      The inspectors sampled licensee submittals for the unplanned scrams with
      complications performance indicator for the period from first quarter 2010 through the
      fourth quarter 2010. To determine the accuracy of the performance indicator data
      reported during those periods, the inspectors used definitions and guidance contained in
      NEI Document 99-02, Regulatory Assessment Performance Indicator Guideline,
      Revision 6. The inspectors reviewed the licensees operator narrative logs, condition
      reports, event reports, and NRC integrated inspection reports for the period of January
      2010 through December 2010 to validate the accuracy of the submittals. The inspectors
      also reviewed the licensees condition report database to determine if any problems had
      been identified with the performance indicator data collected or transmitted for this
      indicator and none were identified. Specific documents reviewed are described in the
      attachment to this report.
      These activities constitute completion of one unplanned scrams with complications
      sample as defined in Inspection Procedure 71151-05.
  b. Findings
      No findings were identified.
.4    Unplanned Power Changes per 7000 Critical Hours (IE03)
  a. Inspection Scope
      The inspectors sampled licensee submittals for the unplanned power changes per 7000
      critical hours performance indicator for the period from first quarter 2010 through the
      fourth quarter 2010. To determine the accuracy of the performance indicator data
      reported during those periods, the inspectors used definitions and guidance contained in
      NEI Document 99-02, Regulatory Assessment Performance Indicator Guideline,
      Revision 6. The inspectors reviewed the licensees operator narrative logs, condition
      reports, event reports, and NRC integrated inspection reports for the period of January
      2010 through December 2010 to validate the accuracy of the submittals. The inspectors
      also reviewed the licensees condition report database to determine if any problems had
      been identified with the performance indicator data collected or transmitted for this
      indicator and none were identified. Specific documents reviewed are described in the
      attachment to this report.
      These activities constitute completion of one unplanned transients per 7000 critical
      hours sample as defined in Inspection Procedure 71151-05.
                                        - 27 -                                Enclosure
  b. Findings
      No findings were identified.
.5    Occupational Exposure Control Effectiveness (OR01)
  a. Inspection Scope
      The inspectors reviewed performance indicator data for the second quarter of 2010
      through the fourth quarter of 2010. The objective of the inspection was to determine the
      accuracy and completeness of the performance indicator data reported during these
      periods. The inspectors used the definitions and clarifying notes contained in NEI
      Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 6,
      as criteria for determining whether the licensee was in compliance.
      The inspectors reviewed corrective action program records associated with high
      radiation area (greater than 1 rem/hr) and very high radiation area non-conformances.
      The inspectors reviewed radiological, controlled area exit transactions greater than
      100 mrem. The inspectors also conducted walkdowns of high radiation areas (greater
      than 1 rem/hr) and very high radiation area entrances to determine the adequacy of the
      controls of these areas.
      These activities constitute completion of the occupational exposure control effectiveness
      sample as defined in Inspection Procedure 71151-05.
  b. Findings
      No findings were identified.
.6    Radiological Effluent Technical Specifications/Offsite Dose Calculation Manual
      Radiological Effluent Occurrences (PR01)
  a. Inspection Scope
      The inspectors reviewed performance indicator data for the second quarter of 2010
      through the fourth quarter of 2010. The objective of the inspection was to determine the
      accuracy and completeness of the performance indicator data reported during these
      periods. The inspectors used the definitions and clarifying notes contained in NEI
      Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 6,
      as criteria for determining whether the licensee was in compliance.
      The inspectors reviewed the licensees corrective action program records and selected
      individual annual or special reports to identify potential occurrences such as
      unmonitored, uncontrolled, or improperly calculated effluent releases that may have
      impacted offsite dose.
                                          - 28 -                                Enclosure
      These activities constitute completion of the radiological effluent technical
      specifications/offsite dose calculation manual radiological effluent occurrences sample
      as defined in Inspection Procedure 71151-05.
  b. Findings
      No findings were identified.
4OA2 Identification and Resolution of Problems (71152)
      Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity, Emergency
      Preparedness, Public Radiation Safety, Occupational Radiation Safety, and
      Physical Protection
.1    Routine Review of Identification and Resolution of Problems
  a. Inspection Scope
      As part of the various baseline inspection procedures discussed in previous sections of
      this report, the inspectors routinely reviewed issues during baseline inspection activities
      and plant status reviews to verify that they were being entered into the licensees
      corrective action program at an appropriate threshold, that adequate attention was being
      given to timely corrective actions, and that adverse trends were identified and
      addressed. The inspectors reviewed attributes that included the complete and accurate
      identification of the problem; the timely correction, commensurate with the safety
      significance; the evaluation and disposition of performance issues, generic implications,
      common causes, contributing factors, root causes, extent of condition reviews, and
      previous occurrences reviews; and the classification, prioritization, focus, and timeliness
      of corrective actions. Minor issues entered into the licensees corrective action program
      because of the inspectors observations are included in the attached list of documents
      reviewed.
      These routine reviews for the identification and resolution of problems did not constitute
      any additional inspection samples. Instead, by procedure, they were considered an
      integral part of the inspections performed during the quarter and documented in
      Section 1 of this report.
  b. Findings
      No findings were identified.
.2    Daily Corrective Action Program Reviews
  a. Inspection Scope
      In order to assist with the identification of repetitive equipment failures and specific
      human performance issues for follow-up, the inspectors performed a daily screening of
                                            - 29 -                                Enclosure
      items entered into the licensees corrective action program. The inspectors
      accomplished this through review of the stations daily corrective action documents.
      The inspectors performed these daily reviews as part of their daily plant status
      monitoring activities and, as such, did not constitute any separate inspection samples.
  b. Findings
      No findings were identified.
.3    Selected Issue Follow-up Inspection
  a. Inspection Scope
      During a review of items entered in the licensees corrective action program, the
      inspectors recognized CR-GGN- 2009-05879 a corrective action item documenting
      temperature switches for safety related ventilation system. The inspectors reviewed that
      item as described in Inspection Procedure 71152.02 to verify, in part, licensee evaluation
      and disposition of operability and reportability issues; consideration of extent of condition
      and cause, generic implications, common cause, and previous occurrences;
      classification and prioritization of the problems resolution commensurate with the safety
      significance; and identification of corrective actions that were appropriately focused to
      correct the problem.
      These activities constitute completion of one in-depth problem identification and
      resolution sample as defined in Inspection Procedure 71152-05.
  b. Findings
      No findings were identified.
4OA3 Event Follow-up (71153)
.1    (Closed) LER 05000416/2010-002-00, Control Room Air Conditioning Inoperability -
      Loss of Both Trains
  a. Inspection Scope
      On October 14, 2010, while operating at approximately 100 percent power, the train B
      control room air conditioner subsystem tripped on low oil pressure while the train A
      control room air conditioner subsystem was out of service for maintenance. The control
      room temperature increased and actions were taken to maintain control room
      temperatures below the technical specification limit of 90 degrees Fahrenheit. The two
      control room air conditioning subsystems were inoperable for 64 hours and 24 minutes
      until the train A control room air conditioner was declared operable.
      The three possible failure mechanisms that the licensee identified in their root cause
      evaluation were 1) the intermittent failure of the low oil differential pressure switch, 2) the
                                            - 30 -                                Enclosure
  intermittent failure of one or more loading/unloading mechanisms, and 3) one or more of
  the temperature control valves were in an open condition or in a more than desired open
  position. The licensee also identified a contributing cause of failure to exclude foreign
  material during maintenance activities on the train B control room air conditioner.
  Inspectors reviewed the circumstances surrounding the event, the licensees response
  to the event, and the licensees corrective actions to preclude repetition. Documents
  reviewed as part of this inspection are listed in the attachment. The enforcement
  aspects of this finding are discussed in this section and in Section 1R12. This LER is
  closed.
b. Findings
  Introduction. The inspectors reviewed a self-revealing, Green noncited violation of 10
  CFR Part 50, Appendix B, Criterion XVI, Corrective Action, after the licensee failed to
  determine the cause and prevent recurrence of a significant condition adverse to quality
  associated with the train B control room air conditioner compressor tripping due to low oil
  pressure.
  Description. On October 14, 2010, the train B control room air conditioner subsystem
  tripped on low oil pressure while the train A control room air conditioner subsystem was
  out of service for maintenance. The control room temperature increased, and actions
  were taken to maintain control room temperatures below the technical specification limit
  of 90 degrees Fahrenheit. The licensee determined that the event (i.e., one subsystem
  inoperable and unavailable for maintenance while the other subsystem was inoperable
  due to a trip) was reportable to the NRC. The two control room air conditioning
  subsystems were inoperable for 64 hours and 24 minutes until the train A control room
  air conditioner was declared operable. This was a significant condition because it
  rendered technical specification required equipment inoperable.
  The licensees corrective actions to address the event involved performing a root cause
  evaluation. The licensee concluded that the three possible failure mechanisms were 1)
  an intermittent failure of low oil differential pressure switch, 2) an intermittent failure of
  one or more loading/unloading mechanisms, and 3) failure of one or more thermal
  expansion valves. The licensee also concluded that a contributing cause of the event
  was the failure to exclude foreign material during maintenance activities of the system.
  The licensee addressed each of the possible root causes, as well as the contributing
  cause, since a single root cause could not be determined. The corrective action for the
  three probable root causes included 1) ensuring that only original differential pressure
  switches are used (or a suitable equivalent) for replacement; 2) revising planned
  maintenance tasks to included instructions for the loader/unloader disassembly,
  inspection and reassembly; 3) revising tasks for compressor A and B rebuilds; and 4)
  revising compressor preventative maintenance tasks to record the degree of superheat
  for each thermal expansion valve.
  Despite the corrective actions implemented by the licensee, the train B control room air
  conditioner compressor again tripped on December 13, 2010, due to low oil pressure.
  After this trip and upon further evaluation, the licensee performed an additional
  corrective action that installed an inline suction filter with smaller filtering diameter and
                                          - 31 -                                  Enclosure
larger surface area to remove foreign material from the system. The licensee also
modified the operator rounds to obtain daily readings of differential pressure across this
new filter and through calculation, determined a differential pressure necessary to
change the filter. The condition report that documented the December 13th event was
closed to the corrective actions associated with the October 14th compressor trip and the
new corrective action associated with the newly installed in line suction filter.
The licensee entered this event into their corrective actions program as condition report
CR-GGN-2010-07315. Since the use of the new inline suction filter, they have not had
any additional trips of the control room air conditioning B. The April 2011 inspection
showed that the filter had reduced foreign material on the compressor suction strainer by
40 percent from the March 2011 inspection. Also in May 2011, the licensee plans to
boroscope the evaporation section of the air conditioner to search for any other foreign
material.
Analysis. The inspectors determined that the failure to take corrective actions to prevent
recurrence of the train B control room air conditioner compressor tripping due to low oil
pressure was a performance deficiency. This finding was more than minor because it
was associated with the equipment performance attribute of the Mitigating Systems
Cornerstone and adversely affected the cornerstone objective to ensure the availability,
reliability, and capability of systems that respond to initiating events to prevent
undesirable consequences. Using Inspection Manual Chapter 0609, "Significance
Determination Process," Phase 1 worksheets, the inspectors determined that a Phase 2
estimate was required because the finding represented a loss of system safety function.
The plant-specific risk informed notebook does not include the evaluation of risk caused
by the loss of cooling to the main control room. Therefore, the senior reactor analyst
conducted a Phase 3 analysis.
The analyst noted that understanding the risk affect of control room chillers required a
review of the following items:
    *    Loss of offsite power frequency (LOOP): Several alternative methods of cooling
          control room equipment are available provided offsite power is available.
          Therefore, the dominant risk impact of essential chillers is during a loss of offsite
          power. The loss of offsite power frequency documented in the plant-specific
          SPAR model is 3.59 x 10-2/year.
    *    Loss of the opposite train probability (PCH-A): The performance deficiency only
          affected Train B CRAC. Therefore, the Train A would still be available to cool the
          main control room. The generic failure probability for a single train of safety-
          related equipment is approximately 3 x 10-2/demand.
    *    Exposure Period (EXP): Although the Train B CRAC system was placed in
          service without correcting the failure mechanism on November 1, 2010, the
          chiller continued to be utilized and run for much of the time until failure on
          December 13, 2010. The analyst noted that the chiller ran from November 12
          until it failed on December 13, 2010. Therefore, the time that the chiller was
          actually unavailable to perform its 24-hour risk significant mission time was
                                        - 32 -                                Enclosure
              about 48 hours (the last 24 hours of its run and the 24 hours it took to repair).
              This gave an exposure time of 2 days.
          *  Conditional Core Damage Probability (CCDP): In the worst case failure of
              control room air conditioning would result in main control room abandonment.
              The generic CCDP for shutting the reactor down from outside the main control
              room is approximately 0.1.
      The analyst determined that a bounding assessment of the change in core damage
      frequency (CDF), can be calculated as follows:
              CDF = LOOP * PCH-A * EXP * CCDP
                      = 3.59 x 10-2/year * 3 x 10-2/demand * 2 days/365 days/year * 0.1
                      = 5.9 x 10-7
      Based on the above bounding analysis, the analyst determined that the change in core
      damage frequency result was 5.9 x 10-7. This noncited violation was therefore
      determined to be of very low safety significance (Green). This finding had a crosscutting
      aspect in the area of problem identification and resolution associated with the corrective
      action program component because licensee personnel failed to thoroughly evaluate the
      multiple failures of the train B control room air conditioner compressor. [P.1(c)]
      Enforcement. Title 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action,
      states, in part, that in the case of a significant condition adverse to quality, measures
      shall assure that the cause of the condition is determined and corrective action taken to
      preclude repetition. Contrary to the above, plant personnel did not implement corrective
      actions to preclude repetition of a significant condition adverse to quality associated with
      the tripping of the train B control room air conditioning compressor due to low oil
      pressure. Specifically, on December 13, 2010, the train B control room air conditioner
      compressor tripped due to low oil pressure after the licensee had a performed a root
      cause analysis to identify the cause and prevent recurrence of the compressor tripping
      due to low oil pressure. Because the finding was of very low safety significance and has
      been entered into the corrective action program as Condition Report CR-GGN-2010-
      07315, this violation is being treated as a noncited violation, consistent with the NRC
      Enforcement Policy. NCV 05000416/2011002-05, Failure to Prevent Recurrence of
      Control Room Air Conditioner Compressor Tripping Due to Low Oil Pressure.
.2    Steam Leak in the Containment
  a. Inspection Scope
      On November 8, 2010, the inspectors responded to the control room to observe operator
      response to a steam leak in containment. The newly installed mitigation monitoring
      system positive displacement pump ejected the cylinder causing an approximate seven
      gallons per minute reactor coolant leak. The inspectors observed operator actions,
      control room briefs and overall plant response to the event. The inspectors also
                                            - 33 -                                Enclosure
  observed control room indications used to identify abnormal conditions in the
  containment building. Documents reviewed for this inspection are listed in the
  attachment.
b.  Findings
  Introduction. The inspectors reviewed a self-revealing, Green finding of EN-DC-115,
  Engineering Change Process, involving the failure to maintain adequate design control
  measures associated with the installation of the mitigation monitoring system.
  Description. On November 8, 2010, at approximately 5:30 am, a reactor coolant
  pressure boundary failure occurred at the skid mounted Online Noble Chemical -
  Mitigation Monitoring System pump inside primary containment. The positive
  displacement sample pump ejected the pump piston from the housing resulting in an
  approximate 7 gpm leak of reactor coolant. The leak was not detected for approximately
  4.5 hours, resulting in the release of approximately 2,000 gallons of reactor coolant
  which flashed directly to steam. The steam leak resulted in a reactor recirculation system
  flow control valve lockup (due to HPU motor failure) and approximately 15,000 square
  feet of contaminated area in the primary containment structure.
  The inspectors reviewed the mitigation monitoring system modification documentation
  and found that the design documentation did not appropriately address the design
  requirements for the installation of the mitigation monitoring system pump. The licensee
  failed to ensure proper validation testing for the pump prior to installation in the plant.
  Specifically, they did not ensure that the pump would be able to withstand the system
  operating pressures and temperatures in which it was installed. They failed to validate
  the design, which had a single point vulnerability, that resulted in the piston injecting
  from the pump and caused the leakage and contamination of the containment. In
  addition, the inspectors reviewed the root cause analysis of the event and found that the
  licensee failed to apply the appropriate oversight of the engineering vendor due to
  weaknesses in the procedure EN-DC-114, "Vendor Quality Management/Oversight."
  The licensee entered this event into their corrective actions program as condition report
  CR-GGN-2010-07852. The licensee has currently removed the mitigation monitoring
  system pump from the plant, and isolated the mitigation monitoring system skid from the
  reactor water cleanup system. They are evaluating the design to make appropriate
  changes to ensure a repeat of this event will not occur.
  Analysis. The failure to implement adequate design control measures for modifications
  to the plant, which impacted the reactor coolant pressure boundary, is a performance
  deficiency. Specifically procedure EN-DC-115, Engineering Change Process, step
  5.1[1], requires during the engineering change development a choice of new technology
  or application is an error precursor which will need to have defensive functions built into
  the design, testing and maintenance, including developing in-house expertise. Contrary
  to this, the engineering change package that implemented this design change failed to
  ensure proper validation testing was performed prior to installation in the plant. The
  finding is more than minor because it affects the design control attribute of the Barrier
  Integrity Cornerstone to provide reasonable assurance that physical design barriers
                                        - 34 -                                Enclosure
      protect the public from radionuclide releases caused by accidents or events. Therefore,
      using inspection Manual Chapter 0609, "Significance Determination Process," Phase 1
      Worksheet for LOCA initiators, the inspectors concluded that the finding was of very low
      safety significance (Green) because the failure of the mitigation monitoring system would
      not have exceeded technical specifications limits for identified leakage in the reactor
      coolant system. This finding has a crosscutting aspect in the area of human
      performance associated with the work practices component because the licensee failed
      to adequately oversee the design of the mitigation monitor system such that nuclear
      safety is supported. [H.4(c)]
      Enforcement. No violation of regulatory requirements occurred. This finding was
      entered into the licensees corrective action program as CR-GGN-2010-07852, and is
      identified as: FIN 05000416/2011002-06, Inadequate Design Control for the Mitigation
      Monitoring System Modification.
4OA5 Other Activities
1.    (Closed) Temporary Instruction (TI) 2515/179, Verification of Licensee Responses to
      NRC Requirement for Inventories of Materials Tracked in the National Source Tracking
      System Pursuant to Title 10, Code of Federal Regulations, Part 20.2207 (10 CFR
      20.2207)
  a.  Inspection Scope
      An NRC inspection was performed to confirm that the licensee has reported their initial
      inventories of sealed sources pursuant to 10 CFR 20.2207 and to verify that the National
      Source Tracking System database correctly reflects the Category 1 and 2 sealed
      sources in custody of the licensee. Inspectors interviewed personnel and performed the
      following:
      *      Reviewed the licensees source inventory
      *      Verified the presence of any Category 1 or 2 sources
      *      Reviewed procedures for and evaluated the effectiveness of storage and handling
            of sources
      *      Reviewed documents involving transactions of sources
      *      Reviewed adequacy of licensee maintenance, posting, and labeling of nationally
            tracked sources
  b.  Findings
      While comparing the National Source Tracking System database information, the
      Licensees information submittal, and original source certificates, the inspector noted
      that the licensee erroneously reported information for one of the four sources meeting
      the reporting criteria. The licensee used original leak test data and submitted the wrong
                                          - 35 -                                Enclosure
        serial number and activity date for the source. The licensee reviewed all relevant data
        and submitted corrected documents within the five business days allowed by
        10 CFR 20.2207(g). This finding was considered as an administrative error and of minor
        safety significance.
4OA6 Meetings
Exit Meeting Summary
On February 18, 2011, the inspectors presented the results of the radiation safety inspections to
Mr. J. Browning, General Plant Manager, and other members of the licensee staff. The licensee
acknowledged the issues presented. The inspectors asked the licensee whether any materials
examined during the inspection should be considered proprietary. No proprietary information
was identified.
On April 14, 2011, the inspectors presented the inspection results to M. Perito, Site Vice-
President Operations and other members of the licensee staff. The licensee acknowledged the
issues presented. The inspector asked the licensee whether any materials examined during the
inspection should be considered proprietary. No proprietary information was identified.
4OA7 Licensee-Identified Violations
The following violations of very low safety significance (Green) were identified by the licensee
and are violations of NRC requirements which meet the criteria of Section 2.3.2 of the NRC
Enforcement Policy for being dispositioned as noncited violations.
.1      Technical Requirements Manual (TRM) section 6.2.1 requires that fire detection
        instrumentation for each fire detection zone shall be operable and if the required
        detection system is inoperable an hourly fire watch must be established. Contrary to
        this, on February 9, 2011 the licensee identified that fire detection instrumentation for fire
        zone 2-12 had been left in the non-audible alarm for the main control room on the fire
        computer when the limiting condition for operations was cleared on December 8, 2010
        when zone was returned to operable status. The control room supervisor on February 9,
        2011, discovered this condition when entering a fire-limiting condition for operation for
        the division 1 diesel generator room to allow welding. The licensee determined that it
        had been in non-audible status from December 8, 2010, through February 9, 2011. This
        issue was documented in the licensees corrective action program in condition report
        CR-GGN-2011-00851. The senior reactor analyst from region IV performed a bounding
        evaluation of the change in risk caused by this condition. According to the Grand Gulf
        Updated Final Safety Analysis Report, Fire Zone 2-12 only contains Division I
        equipment. A fire that consumed the equipment in the area could not result in a loss of
        offsite power or other unplanned transient. Given the ignition frequency of the area, the
        60-day exposure period, and the conditional core damage probability with the loss of the
        Division I emergency diesel generator, the analyst calculated that the change in risk was
        significantly less than 1E-6. Therefore, this finding was of very low safety significance
        (Green).
                                            - 36 -                                  Enclosure
- 37 - Enclosure
                                SUPPLEMENTAL INFORMATION
                                  KEY POINTS OF CONTACT
Licensee Personnel
R. Benson, Manager (Acting), Radiation Protection
J. Browning, General Plant Manager
D. Coulter, Senior Licensing Specialist
H Farris, Assistant Operation Manager
K. Higgenbotham, Planning and Scheduling Manager
J. Houston, Maintenance Manager
R. Jackson, Licensing
C. Lewis, Manager, Emergency Preparedness
C. Perino, Licensing Manager
M. Perito, Site Vice President of Operations
M. Richey, Director, Nuclear Safety Assurance
F. Rosser, Supervisor, Dosimetry
R. Sumrall, Superintendant, Operations Training
R. Sylvan, Supervisor, Radiation Protection
T. Trichell, Radiation Protection Manager
D. Wiles, Engineering Director
R. Wilson, Manager, Quality Assurance
E. Wright, Supervisor, Radiation Protection
NRC Personnel
R. Smith, Senior Resident Inspector
                                          A-1            Attachment
                  LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED
Opened and Closed
                            Transient Combustible Stored in the Fire Exclusion Zone Near the
05000416/2011002-01 NCV
                            Independent Spent Fuel Storage Installation (Section 1R05)
                            Failure to Update Available Low Pressure Coolant Injection Loops
05000416/2011002-02 NCV
                            in the Updated Final Safety Analysis Report (Section 1R12)
                            Failure to Demonstrate Maintenance Effectiveness of Train B
05000416/2011002-03 NCV
                            Control Room Air Conditioner(Section 1R12)
                            Failure to Use a Qualified Radiation Protection Technician to
05000416/2011002-04 NCV    Provide Direct Continuous Coverage of Work in a Locked High
                            Radiation Area (Section 2RS01)
                            Failure to Prevent Recurrence of Control Room Air Conditioner
05000416/2011002-05 NCV
                            Compressor Tripping Due to Low Oil Pressure (Section 4OA3)
                            Inadequate Design Control for the Mitigation Monitoring System
05000416/2011002-06 FIN
                            Modification (Section 4OA3)
Closed
                            Verification of Licensee Responses to NRC Requirement for
                            Inventories of Materials Tracked in the National Source Tracking
TI 2515/179            TI
                            System Pursuant to Title 10, Code of Federal Regulations,
                            Part 20.2207 (10 CFR 20.2207) (Section 4OA5)
05000416/2010-002-00 LER Control Room Air Conditioning Inoperability - Loss of Both Trains
                            (Section 4OA3)
                                        A-2                                  Attachment
                          LIST OF DOCUMENTS REVIEWED
Section 1RO1: Adverse Weather Protection
PROCEDURE
    NUMBER                                TITLE                      REVISION
ENS-EP-302      Severe Weather Response                                  11
05-1-02-VI-2    Hurricanes, Tornados, and Severe Weather                113
04-1-01-P41-1  Standby Service Water System                            133
04-1-01-N71-1  Circulating Water System                                  72
04-1-03-A30-1  Cold Weather Protection                                  20
OTHER
    NUMBER                                TITLE                        DATE
                SSW Pump Discharge Temperatures                    January 6-10,
                                                                        2011
WORK ORDER
WO 52233022
Section 1RO4: Equipment Alignment
PROCEDURE
    NUMBER                                TITLE                      REVISION
9.3-17 - 9.3-25 GG UFSAR                                                  3
07-1-34-C41-    Standby Liquid Control Pump                              10
C001-1
04-1-01-C41-1  Standby Liquid Control System                            119
04-1-01-P75-1  Standby Diesel Generator System                          88
04-1-01-P41-1  Standby Service Water System                            133
04-1-01-E12-1  System Operating Instructions Residual Heat Removal      137
                System
04-1-01-E12-1  Residual Heat Removal B                                  137
04-1-01-E12-1  Residual Heat Removal C                                  137
                                      A-3                          Attachment
PROCEDURE
    NUMBER                                    TITLE                          REVISION
04-1-01-E12-1      Residual Heat Removal B Attachment IB                        137
04-1-01-E12-1      Residual Heat Removal B Attachment IIIB                      137
04-1-01-E12-1      Residual Heat Removal C Attachment IC                        137
04-1-01-E12-1      Residual Heat Removal B Attachment VB                        137
04-1-01-E12-1      Residual Heat Removal (Interface Valves) Attachment IIE      137
04-1-01-P41-1      Standby Service Water System Attachment IIB                  133
04-1-01-P41-1      Standby Service Water System Attachment IIIB                  113
OTHER
    NUMBER                                    TITLE                            DATE
11-4568            Scaffolding Evaluation Request                          February 15,
                                                                                2001
CALCULATION
    NUMBER                                    TITLE                            DATE
9645              Diesel Generator Building Walls                          August 2,
                                                                                1976
C-C400            SSW CT and Basin (Pump-House) Tornado and No            May 28, 1976
                  Earthquake
C-0-100            Diesel Generator Bldg. Walls Tornado Wind Load W        August 2,
                                                                                1976
WORK ORDER
WO 52256371                        WO 00260559                  WO 00259801
Section 1RO5: Fire Protection
PROCEDURE
      NUMBER                                    TITLE                        REVISION
Fire Pre-Plan DG-03    Division II Diesel Generator Room                          3
9A-343 - 9A347        GG UFSAR
Fire Pre-Plan A-02    RHR A Pump Room 1A103                                      1
                                          A-4                              Attachment
PROCEDURE
      NUMBER                                    TITLE                          REVISION
Fire Pre-Plan A-03    RCIC Pump Room 1A104                                          1
Fire Pre-Plan A-04    RHR B Pump Room 1A105                                        1
9A.5.2.2              Safe Shutdown Equipment
Appendix 9B            Fire Protection Program
CONDITION REPORT
CR-GGN-2011-00862                CR-GGN-2011-01939              CR-GGN-2011-00851
CR-GGN-2011-00455
Section 1RO6: Flood Protection Measures
PROCEDURE
    NUMBER                                    TITLE                          REVISION /
                                                                                  DATE
9A-336 - 9A338    GG UFSAR
9A.5.59            GG UFSAR FIRE AREA 59
EN-OP-104          Operability Determination Process Immediate Determination        4
                  For Degraded of Nonconforming Conditions
OTHER
    NUMBER                                    TITLE                              DATE
                  Russell Daniel Oil Co. Inc. Delivery Date Schedule          February 10,
                                                                                  2011
CONDITION REPORT
CR-GGN-2011-00198                CR-GGN-2011-00562              CR-GGN-2011-00654
WORK ORDER
WO 52281566                      WO 52210679 03                  WO 52210679 02
WO 52210679 01                  WO 00041743                    WO 52210679
                                          A-5                                Attachment
ENGINEERING CHANGE
EC No. 24971                  EC No. 24904                  EC No. 24972
Section 1R07:
PROCEDURE
    NUMBER                                  TITLE                            REVISION
08-S-03-10      Chemistry Procedure-Closed Loops                                48
OTHER
    NUMBER                                  TITLE                              DATE
CCE 2006-0002    Commitment Change Evaluation Form
Letter          Response to Generic Letter 89-13; Service Water System      January 29,
                Problems Affecting Safety-Related Equipment                    1990
WORK ORDER
WO 00178965 01                WO 00178965 02                WO 00178965 03
Section 1R11: Licensed Operator Requalification Program
OTHER
    NUMBER                                  TITLE                          REVISION /
                                                                                DATE
GSMS-LOR-        LOR Training-Double Recirculation Pump Trip/ATWS            January 18,
WEX03                                                                          2011
                                                                              Rev 17
                Turnover and Simulator Differences 2011 Cycle 1 Simulator        1
                Training
                Per Control Room Walkdown, Modifications to TREX Load        January 7,
                                                                                2011
Letter          Emergency Preparedness January 31, 2011 Simulator Drill    February 1,
                Performance Indicators                                        2011
                                        A-6                                Attachment
Section 1R12: Maintenance Effectiveness
PROCEDURE
    NUMBER                                  TITLE                        REVISION /
                                                                              DATE
EN-FP-S-001-    Engineering Standard-Appendix R Emergency Lighting Units    January 10,
Multi                                                                          2011
07-S-12-143    Big Beam Emergency Light Inspection, Battery Capacity            2
                Verification, and Functional Test
EN-DC-203      Maintenance Rule Program                                        1
EN-DC-206      Maintenance Rule (a)(1) Process                                  1
EN-DC-207      Maintenance Rule Periodic Assessment                            1
NMM EN-LI-118  Root Cause Evaluation Report Attachment IV (54 of 54)            12
EN-DC-205      Maintenance Rule Monitoring                                      2
                GG UFSAR Table 7.5-1 Safety-Related Display
                Instrumentation
                GG UFSAR Table 7.5-2 Post-Accident Monitoring
                Instrumentation
                GG UFSAR 6.3 Emergency Core Cooling Systems                      0
03-1-01-3      Integrated Operating Instructions Plant Shutdown                118
OTHER
    NUMBER                                  TITLE                        REVISION /
                                                                              DATE
                Emergency Lighting - GGNS Discussion of Recent Activities
                Maintenance Rule Expert Panel June 22, 2010 Meeting
                Minutes
                Maintenance Rule Expert Panel August 10, 2010 Meeting
                Minutes
                Entergy Nuclear-GGNS Maintenance Rule Program Basis              0
                Document, Control Room and Emergency Lighting (Z92)
                System
Z92            Maintenance Rule Database Control Room and Emergency
                Lighting
TM M348X.8001  Midtron 3200 Battery Conductance Tester
                                        A-7                              Attachment
OTHER
  NUMBER                                TITLE                            REVISION /
                                                                                DATE
VMA97/0181    Emergency Lights
              Maintenance Rule Database Information - Main Control          March 21,
              Room Air Conditioning (Z51) System                              2009 to
                                                                              December
                                                                              23, 2010
              Maintenance Rule Database Z51 Control Room HVAC
              System
EC No.: 27856  Engineering Evaluation                                              0
              Maintenance Rule Program (a)(1) Evaluation and Action Plan
              Main Control Room Air Conditioning (Z51) System
              Agenda for Maintenance Rule Expert Panel Meeting              February 4,
                                                                                2010
              RHR Heat Exchanger SSW Flow Indication (a)(1) Status
              Maintenance Rule Database E12 RHR System
              Maintenance Rule Program (a)(1) Evaluation for the Residual
              Heat Removal (E12/RHR) System CR-GGN-2009-0754 CA
              No. 002
              Maintenance Rule (a)(1) Evaluation Standby Service Water
              (P41) System (GR-GGN-2010-00305)
              Agenda Items from Maintenance Rule Expert Panel Meeting        June 24,
                                                                                2010
              Agenda Items from Maintenance Rule Expert Panel Meeting        June 22,
                                                                                2010
CONDITION REPORT
CR-GGN -2009-05330          CR-GGN -2010-00381            CR-GGN -2010-04575
CR-GGN -2010-04585          CR-GGN -2010-06346            CR-GGN -2011-00481
CR-GGN -2011-00521          CR-GGN -2011-01212            CR-GGN-2011-01650
CR-GGN-2010-01984          CR-GGN-2011-11505              CR-GGN-2011-01308
CR-GGN-2010-07315          CR-GGN-2009-00842              CR-GGN-2009-00754
GR-GGN-2009-01729          CR-GGN-2009-02477              CR-GGN-2009-03394
CR-GGN-2009-02947          CR-GGN-2009-02848              CR-GGN-2009-03292
CR-GGN-2009-03574          CR-GGN-2009-03592              CR-GGN-2009-04219
                                      A-8                                  Attachment
CR-GGN-2010-01031            CR-GGN-2009-04048            CR-GGN-2009-05930
CR-GGN-2009-05215            CR-GGN-2009-05932            CR-GGN-2009-05472
CR-GGN-2009-06066            CR-GGN-2009-04733            CR-GGN-2010-00036
CR-GGN-2010-01329            CR-GGN-2011-00789            CR-GGN-2010-07351
CR-GGN-2010-04009            CR-GGN-2010-05892            CR-GGN-2011-00791
CR-GGN-2011-00820            CR-GGN-2011-00985            CR-GGN-2009-01204
CR-GGN-2010-00684            CR-GGN-2010-05290            CR-GGN-2010-01585
CR-GGN-2010-00800            CR-GGN-2010-01474            CR-GGN-2010-01337
CR-GGN-2009-05508            CR-GGN-2010-01320            CR-GGN-2010-01345
CR-GGN-2009-05731            CR-GGN-2009-06174            CR-GGN-2010-02797
CR-GGN-2010-02200            CR-GGN-2010-03655            CR-GGN-2010-04629
CR-GGN-2010-02990            CR-GGN-2010-03241            CR-GGN-2009-00350
CR-GGN-2009-00426            CR-GGN-2009-00846            CR-GGN-2009-01518
CR-GGN-2010-02805            CR-GGN-2010-04015            CR-GGN-2010-03333
CR-GGN-2010-04625            CR-GGN-2010-04255            CR-GGN-2009-05527
CR-GGN-2010-02974            CR-GGN-2010-06137            CR-GGN-2010-05208
CR-GGN-2010-05330            CR-GGN-2010-04686            CR-GGN-2010-04963
CR-GGN-2010-05572            CR-GGN-2010-03650            CR-GGN-2010-06978
CR-GGN-2010-06148            CR-GGN-2010-06150            CR-GGN-2010-05328
CR-GGN-2010-06142            CR-GGN-2011-00403            CR-GGN-2011-00749
CR-GGN-2011-00819            CR-GGN-2011-00850            CR-GGN-2010-06895
CR-GGN-2010-06918            CR-GGN-2011-01212            CR-GGN-2010-05147
WORK ORDER
WO 52255810                  WO 52223396                  WO 52271013 01
WO 52196016                  WO 52220690
Section 1R13: Maintenance Risk Assessment and Emergent Work Controls
PROCEDURE
  NUMBER                                TITLE                            REVISION
EN-WM-101      On-line Work Management Process                                7
EN-WM-100      Work Request Generation, Screening and Classification          5
EN-WM-101      On-line Work Management Process                                8
EN-WM-101      On Line Emergent Work Addition/Deletion Approval Form for      7
                the Week of March 7, 2011
                                      A-9                                Attachment
PROCEDURE
  NUMBER                                TITLE                            REVISION
EN-WM-101      On Line Emergent Work Addition/Deletion Approval Form for      7
                the Week of February 28, 2011
WORK ORDER
WO250074                    WO247598                      WO52290243
WO52290462                  WO52290463                    WO52290464
WO70346                      WO52291451                    WO52291458
WO52291454                  WO52291456                    WO52291689
WO52291690                  WO261213                      WO52284287
WO52269835                  WO52290236                    WO52290463
WO52290464                  WO52291844                    WO52291454
WO52291456                  WO261601                      WO250966-02
WO237429                    WO256910-01                  WO52290639
WO52287735                  WO52290638                    WO52287736
WO52276935                  WO260417                      WO260212-02
WO260212-01                  WO00219198                    WO260529-07
WO52204865                  WO260503                      WO52243284
WO260529-07                  WO52204865                    WO52199495
WO255787-01,02,03,04        WO52249417                    WO52271012
WO261175                    WO259639                      WO257881
WO200935-02                  WO00257063                    WO224859
WO261706                    WO255360-08                  WO263130
WO261181-01 and 02          WO262143                      WO234988-04
WO234992-04                  WO52250110-03                WO234985-04
WO259003-05                  WO259005-05                  WO259007-05
WO112951-08                  WO52270042                    WO52259286
WO52275616                  WO52288663                    WO52290468
WO52270252                  WO52291424                    WO52270250
WO52291423                  WO235034                      WO52288844
WO51563342                  WO160041                      WO52290473
WO52281103
                                    A-10                                Attachment
Section 1R15: Operability Evaluations
PROCEDURE
    NUMBER                                  TITLE                            REVISION
EN-OP-104      Operability Determination Process                                  4
EN-DC-115      EC No. 20228                                                      0
CALCULATION
    NUMBER                                  TITLE                            REVISION
PDS0170B        SSW Basin A Relief Valve                                        2
DRAWING
    NUMBER                                  TITLE                            REVISION
FSK-M-KC187-    Design Change Drawing SSW Basin A and B                        8
01C1-Y
                Design Change Drawing Reinforced Concrete Distribution            8
                Support System Tower Elevation 157-8
OTHER
    NUMBER                                  TITLE                            REVISION /
                                                                                DATE
2007-029        LBDCR Initiation
                Grand Gulf Nuclear Station, Unity 1 - Conforming License    July 18, 2007
                Amendment to Incorporate the Mitigation Strategies Required
                by Section B.5.b of the Commission Order EA - 02 - 026
GNRO-          Supplementary Response Regarding Implementation Details      June 7, 2007
2007/00037      for the Phase 2 and 3 Mitigation Strategies Grand Gulf
                Nuclear Station
NEI 06-12      B.5.b Phase 2 & 3 Submittal Guideline                          Rev 2
                                                                              December
                                                                                2006
7-15            GG FSAR                                                        Rev 59
9.5-3          GG UFSAR
Attachment 9.2  Immediate Determination for Degraded of Nonconforming
                Conditions CR-GGN-2011-01512
                                      A-11                                Attachment
OTHER
    NUMBER                                  TITLE                        REVISION /
                                                                            DATE
Attachment 9.5  Operability Evaluation CR-GGN-2011-00155
                NUS Switch Status
CONDITION REPORT
CR-GGN-2011-01173              CR-GGN-2011-00765            CR-GGN-2011-00155
CR-GGN-2011-00766              CR-GGN-2011-00799            CR-GGN-2011-01512
CR-GGN-2009-06838              CR-GGN-2011-01349            CR-GGN-2011-04701
CR-GGN-2011-00369              CR-GGN-2011-00643            CR-GGN-2011-00647
CR-GGN-2011-00665              CR-GGN-2011-00666            CR-GGN-2011-00667
CR-GGN-2011-00668              CR-GGN-2011-00669            CR-GGN-2011-00670
CR-GGN-2011-00671
Section 1R18: Plant Modifications
PROCEDURE
    NUMBER                                TITLE                          REVISION
EN-DC-136      Temporary Modifications                                        5
EN-LI-102      Corrective Action Process                                    16
DRAWING
    NUMBER                                  TITLE                        REVISION
E-1187-007      E31 Leak Detection System RWCU Flow Circuit Computer          7
                Input
E1165014        Schematic Design Rod Control and Information System Rod      13
                Position Information and SCRAM Time Test
E1173028        Schematic Design Reactor Protection System Testability        6
M1051A          Main and Reheat System                                        33
OTHER
    NUMBER                                  TITLE
                06-OP-1000-D-0001 Log Data
                                        A-12                            Attachment
OTHER
    NUMBER                                  TITLE
CR-GGN-2009-    CR Periodic Review (initial at 6 months/follow by annual)
02198 CA 26    and/or Long Tem CA Classification Form
CONDITION REPORT
CR-GGN-2009-02198            CR-GGN-2010-04451                CR-GGN-2011-01231
WORK ORDER
WO00238932                    WO00238928                      WO00193921
WO00193920                    WO002239736-01                  WO002239736-02
WO002239736-03
ENGINEERING CHANGE
EC22768                      EC22625                          EC22635
Section 1R19: Postmaintenance Testing
PROCEDURE
    NUMBER                                  TITLE                            REVISION /
                                                                                DATE
06-OP-1E12-Q-  LPCI/RHR Subsystem A MOV Functional Test                        112
0005
06-OP-1E12-Q-  LPCI/RHR Subsystem A Quarterly Functional Test                  121
0023
06-0P-1E12-    LPCI/RHR System B MOV Functional Test                            111
0006
06-OP-1P41-Q-  Standby Service Water Loop A Valve AND Pump Operability          119
0004            Test
04-1-03-P75-1  Div 1 Diesel Generator Unexcited Run                              7
06-OP-1P75-M-  Data Sheet III Standby Diesel Generator 11 Functional Test  February 12,
001                                                                            2011
07-S-12-40      General Cleaning and Inspection of Rotating Electrical            2
                Equipment
07-S-12-146    General Maintenance Instruction Motor Off Line Diagnostic        1
                                      A-13                                Attachment
PROCEDURE
    NUMBER                                TITLE                          REVISION /
                                                                              DATE
              Data Acquisition
07-S-12-55    Insulation Resistance Testing                                    10
06-IC-1E22-Q-  HPCS System Flow Rate - Low (Bypass) Functional Test            104
0004
OTHER
    NUMBER                                TITLE                              DATE
              RPS Motor GEN B - MCE Stator                                February 2,
                                                                              2011
              HPCS Min Flow Valve Position                                March 18,
                                                                              2011
DRAWING
    NUMBER                                TITLE                              DATE
BRKR No. 52-  IC71SOOIOB
142229
BRKR No. 52-  IC7IS003B (Local C71-S003B)
142229
BRKR No. 52-  IC7IS003D (Local C71-S003D)
142229
              Timeline for Events leading to NRC Notification Call on      March 18,
              HPCS                                                          2011
CONDITION REPORT
CR-GGN-2011-00945
WORK ORDER
WO52311451                  WO52311569                      WO52285575
WO00251847                  WO52224645                      WO52223715
WO00262318                  WO00259110-01                  WO00259110-03
WO00237650-01                WO00237650-04                  WO00237650-05
WO00237650-06                WO52304041                      WO00270205-01
                                      A-14                              Attachment
WO00270205-02
Section 1R22: Surveillance Testing
PROCEDURE
    NUMBER                                  TITLE                            REVISION
06-CH-1B21-O-  Reactor Coolant Routine Chemistry-Sample February 23,            106
0002            2011
06-CH-1B21-O-  Reactor Coolant Routine Chemistry-Sample February 18,            106
0002            2011
06-CH-1B21-O-  Plant Operations Manual-Reactor Coolant Routine Chemistry        106
0002
06-CH-1B21-W-  Reactor Coolant Dose Equivalent Iodine                            104
0008
06-OP-1C61-R-  Functional Checks with E51 Valves                                109
0002
06-OP-1P75-M-  Standby Diesel Generator Functional Test                          132
0001
06-IC-1D17-R-  Fuel Handling Area Ventilation Exhaust High High Radiation        102
0010            Electronics Time Response Test
04-1-01-P81-1  High Pressure Core Spray Diesel Generator                          67
06-OP-1P81-M-  HPCS Diesel Generator 13 Functional Test                          123
0002
EN-OP-109      Conduct of Operations                                              2
OTHER
    NUMBER                                  TITLE                                DATE
                Drywell Unidentified Leakage Rate vs. A Recirc Seal Delta  June 2010-
                T                                                            January 2011
CONDITION REPORT
CR-GGN-2011-01932            CR-GGN-2011-01868
WORK ORDER
WO52271012                    WO52289870                    WO52288401
WO52261837                    WO52307262                    WO00270146-01
                                      A-15                                Attachment
Section 1EP6: Drill Evaluation
OTHER
      NUMBER                        TITLE                        DATE
                    Emergency Facility Log                      March 3, 2011
                    Repair and Corrective Action Table          March 3, 2011
Emergency Notification Form 1-7 for EP Drill                    March 3, 2011
GGNS 2011 1st Quarter ERO Training Drill
CONDITION REPORT
CR-GGN-2011-01481              CR-GGN-2011-01486                CR-GGN-2011-01495
CR-GGN-2011-01499              CR-GGN-2011-01510                CR-GGN-2011-01519
CR-GGN-2011-01520              CR-GGN-2011-01522
Section 2RS01: Radiological Hazard Assessment and Exposure Controls
PROCEDURES
    NUMBER                                    TITLE                              REVISION
EN-RP-100        Radiation Worker Expectations                                      6
EN-RP-101        Access Control for Radiologically Controlled Areas                  5
EN-RP-102        Radiological Control                                                2
EN-RP-106        Radiological Survey Documentation                                  2
01-S-08-1        Administration of the GGNS Radiation Protection Program            105
01-S-08-6        Radioactive Source Control                                        113
08-S-02-50      Radiological Surveys and Surveillances                            116
AUDITS, SELF-ASSESSMENTS, AND SURVEILLANCES
    NUMBER                                TITLE                                DATE
LO-GLO-2010-93    Pre-NRC Rad Hazard Assessment and Exposure            December 16, 2010
                  Controls Assessment
CONDITION REPORTS
CR-GGN-2011-00183 CR-GGN-2011-00551 CR-GGN-2011-00655 CR-GGN-2011-00926
CR-GGN-2011-00740
                                        A-16                                  Attachment
RADIOLOGICAL SURVEY
    NUMBER                              TITLE                                DATE
GG-1102-0146    Routine Daily Surveys                                  February 15, 2011
GG-1012-0083    208 CTMT Entire Elevation                              December 7, 2010
GG-1102-0152    208 CTMT Entire Elevation                              February 15, 2011
GG-1012-0118    119 AB RHR A Room                                      December 9, 2010
GG-1012-0086    119 AB RHR A Room                                      February 7, 2011
GG-1011-0254    119 AB RHR B Room                                      November 30, 2010
GG-1101-0156    119 AB RHR B Room                                      January 16, 2011
GG-1011-0064    93 Aux RHR C & ADHR Hx Rooms                            November 6, 2010
GG-1102-0044    93 Aux RHR C & ADHR Hx Rooms                            February 3, 2011
GG-1011-0018    119 Aux Piping Penetration & Valve Room                November 2, 2010
GG-1102-0041    119 Aux Piping Penetration & Valve Room                February 3, 2011
GG-1011-0063    93 Aux HPCS Pump Room                                  November 6, 2010
GG-1102-0042    93 Aux HPCS Pump Room                                  February 3, 2011
RADIATION WORK PERMITS
    NUMBER                                    TITLE
20101005        Tours and Inspections into all areas
20111054        Locked High Radiation Area Entries for Plant/System Investigations, Valve
                Manipulations, Tagouts, and Misc. Activities
20111058        Maintenance in HRA /HCA & Above
Section 2RS02: Occupational ALARA Planning and Controls
PROCEDURES
    NUMBER                                  TITLE                              REVISION
EN-RP-105      Radiological Work Permits                                          9
EN-RP-110      ALARA Program                                                      7
AUDITS, SELF-ASSESSMENTS, AND SURVEILLANCES
    NUMBER                              TITLE                                DATE
LO # LO-GLO-    Pre-NRC Inspection for ALARA Planning and Controls-    November 9, 2010
2010-00094      Assessment
CONDITION REPORTS
                                      A-17                                  Attachment
CR-GGN-2011-00425 CR-GGN-2011-00425 CR-GGN-2010-06335
RADIATION WORK PERMIT PACKAGES
    NUMBER                                  TITLE
2010-1402      Refuel Floor High Water Activities
2010-1403      Reactor Disassemble/Reassemble
2010-1508      Under Vessel Activities
2010-1530      B Recirc Pump Replacement
2010-1534      B21F011B Stem Replacement
Section 4OA1: Performance Indicator Verification
PROCEDURE
  NUMBER                                  TITLE                      REVISION
                st
EN-LI-114      1 Quarter 2010 Unplanned Scrams per 7,000 Critical        4
                Hours
EN-LI-114      2nd Quarter 2010 Unplanned Scrams per 7,000 Critical      4
                Hours
EN-LI-114      3rd Quarter 2010 Unplanned Scrams per 7,000 Critical      4
                Hours
EN-LI-114      4th Quarter 2010 Unplanned Scrams per 7,000 Critical      4
                Hours
EN-LI-114      1st Quarter 2010 Unplanned Scrams with Complications      4
EN-LI-114      2nd Quarter 2010 Unplanned Scrams with Complications      4
EN-LI-114      3rd Quarter 2010 Unplanned Scrams with Complications      4
EN-LI-114      4th Quarter 2010 Unplanned Scrams with Complications      4
EN-LI-114      1st Quarter 2010 Unplanned Power Changes per 7,000        4
                Critical Hours
EN-LI-114      2nd Quarter 2010 Unplanned Power Changes per 7,000        4
                Critical Hours
EN-LI-114      3rd Quarter 2010 Unplanned Power Changes per 7,000        4
                Critical Hours
EN-LI-114      4th Quarter 2010 Unplanned Power Changes per 7,000        4
                Critical Hours
                                        A-18                        Attachment
OTHER
  NUMBER                                  TITLE
                January 2010 Core Thermal Power
                February 2010 Core Thermal Power
                March 2010 Core Thermal Power
                April 2010 Core Thermal Power
                May 2010 Core Thermal Power
                June 2010 Core Thermal Power
                July 2010 Core Thermal Power
                August 2010 Core Thermal Power
                September 2010 Core Thermal Power
                October 2010 Core Thermal Power
                November 2010 Core Thermal Power
                December 2010 Core Thermal Power
Section 4OA2: Identification and Resolution of Problems
OTHER
  NUMBER                                  TITLE                          DATE
                GGNS Position on Riley Temperature Switch Replacement
                Maintenance Rule Program Functional Failures-Riley
                Temperature Switches
                NUS Switch Status                                      February 2,
                                                                          2011
                Riley History Discussion by Lee Eaton
                Riley History Presentation to 2009 PInR
CONDITION REPORT
CR-GGN-2009-05879
                                      A-19                          Attachment
Section 4OA3: Event Follow-Up
PROCEDURE
  NUMBER                                    TITLE                          REVISION
EN-DC-167      Classification of Structures, Systems, and Components              3
EN-HU-103      Human Performance Error Reviews for CR-GGN-2010-7877              4
EN-DC-115      Engineering Change Process                                        11
DRAWINGS
  NUMBER                                    TITLE                          REVISION
M-1127A        Piping and Instrumentation Diagram Noblechem Monitoring            0
                System
M-1081B        Control Rod Drive Hydraulic System                                28
M-1078A        Reactor Recirculation System Unit 1                              33
M-1079          Reactor Water Clean-up System Unit 1                              46
M-1069A        Process Sampling System Unit 1                                    24
OTHER
  NUMBER                                    TITLE                              DATE
                Root Cause Evaluation Report-Control Room Air Conditioner    October 16,
                B Trip (Event Date 10-14-2010)                                  2010
GNRO-          LER 2010-002-00Control Room Air Conditioning                  December
2010/00077                                                                    13, 2010
                Root Cause Evaluation Report Mitigation Monitor Durability  November 8,
                Monitor Pump Failure                                            2010
                MMS Skid Piping/Component Design Basis
                Compliance with NRC Regulatory Guide 1.26
CONDITION REPORT
CR-GGN-2010-07315              CR-GGN-2010-08580              CR-GGN-2010-07852
ENGINEERING CHANGE
                                        A-20                              Attachment
EC13135                        EC13132                        EC13138
Section 4OA5 Temporary Instruction 2515/179
PROCEDURES
    NUMBER                                  TITLE                      REVISION
EN-RP-143        Source Control                                            7
MISCELLANEOUS DOCUMENTS
      TITLE                                                                DATE
National Source Tracking System Annual Inventory Reconciliation Report      2010
National Source Tracking System Annual Inventory Reconciliation Report      2011
Section 4OA7: Licensee-Identified Violations
CONDITION REPORT
CR-GGN-2011-00851
                                        A-21                          Attachment
}}
}}

Latest revision as of 23:52, 12 November 2019

IR 05000416-11-002; on 01/21/2011 03/27/2011; Grand Gulf Nuclear Station, Integrated Resident and Regional Report; Fire Protection, Maintenance Effectiveness, Radiological Hazard Assessment and Exposure Controls, and Event Follow-Up
ML111300462
Person / Time
Site: Grand Gulf Entergy icon.png
Issue date: 05/10/2011
From: Vincent Gaddy
NRC/RGN-IV/DRP/RPB-C
To: Mike Perito
Entergy Operations
References
IR-11-002
Download: ML111300462 (61)


See also: IR 05000416/2011002

Text

UNITED STATES

NUCLEAR REGULATORY COMMISSION

REGI ON I V

612 EAST LAMAR BLVD, SUITE 400

ARLINGTON, TEXAS 76011-4125

May 10, 2011

Mr. Mike Perito

Vice President Operations

Entergy Operations, Inc.

Grand Gulf Nuclear Station

P.O. Box 756

Port Gibson, MS 39150

Subject: GRAND GULF NRC INTEGRATED INSPECTION REPORT NUMBER

05000416/2011002

Dear Mr. Perito:

On March 27, 2011, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection

at your Grand Gulf Nuclear Station. The enclosed integrated inspection report documents the

inspection findings, which were discussed on April 14, 2011, with Mike Perito, Vice President

Operations, and other members of your staff.

The inspections examined activities conducted under your license as they relate to safety and

compliance with the Commissions rules and regulations and with the conditions of your license.

The inspectors reviewed selected procedures and records, observed activities, and interviewed

personnel.

Based on the results of this inspection, the NRC has determined that one Severity Level IV

violation of NRC requirements occurred. The NRC has also identified five issues that were

evaluated under the risk significance determination process as having very low safety

significance (Green). The NRC has determined that four of these findings have violations

associated with these issues. Additionally, one licensee-identified violation, which was

determined to be of very low safety significance, is listed in this report. However, because of

their very low safety significance and because they were entered into your corrective action

program, the NRC is treating these findings as noncited violations, consistent with Section 2.3.2

of the NRC Enforcement Policy.

If you contest the significance of the noncited violations, you should provide a response within

30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear

Regulatory Commission, ATTN: Document Control Desk, Washington, D.C. 20555-0001, with

copies to the Regional Administrator, U.S. Nuclear Regulatory Commission, Region IV,

612 E. Lamar Blvd, Suite 400, Arlington, Texas, 76011-4125; the Director, Office of

Enforcement, U.S. Nuclear Regulatory Commission, Washington, D.C. 20555-0001; and the

NRC Resident Inspector at the facility. In addition, if you disagree with the cross-cutting aspect

assigned to any finding in this report, you should provide a response within 30 days of the date

Entergy Operations, Inc. -2-

of this inspection report, with the basis for your disagreement, to the Regional Administrator,

Region IV, and the NRC Resident Inspector at the facility.

In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, its

enclosures, and your response, if you choose to provide one, will be made available

electronically for public inspection in the NRC Public Document Room or from the NRC's

document system (ADAMS), accessible from the NRC Web site at http://www.nrc.gov/reading-

rm/adams.html. To the extent possible, your response should not include any personal privacy

or proprietary, information so that it can be made available to the Public without redaction.

Sincerely,

/RA/

Vincent Gaddy, Chief

Project Branch C

Division of Reactor Projects

Docket: 50-416

License: NPF-29

Enclosed: NRC Inspection Report 05000416/2011002

w/Attachment: Supplemental Information

Distribution via ListServe

Entergy Operations, Inc. -3-

Electronic distribution by RIV:

Regional Administrator (Elmo.Collins@nrc.gov)

Deputy Regional Administrator (Art.Howell@nrc.gov)

DRP Director (Kriss.Kennedy@nrc.gov)

DRP Deputy Director (Troy.Pruett@nrc.gov)

DRS Director (Anton.Vegel@nrc.gov)

Senior Resident Inspector (Rich.Smith@nrc.gov)

Branch Chief, DRP/C (Vincent.Gaddy@nrc.gov)

Senior Project Engineer, DRP/C (Bob.Hagar@nrc.gov)

Project Engineer, DRP/C (Rayomand.Kumana@nrc.gov)

GG Administrative Assistant (Alley.Farrell@nrc.gov)

Public Affairs Officer (Victor.Dricks@nrc.gov)

Public Affairs Officer (Lara.Uselding@nrc.gov)

Project Manager (Alan.Wang@nrc.gov)

Branch Chief, DRS/TSB (Michael.Hay@nrc.gov)

RITS Coordinator (Marisa.Herrera@nrc.gov)

Regional Counsel (Karla.Fuller@nrc.gov)

Congressional Affairs Officer (Jenny.Weil@nrc.gov)

RIV OEDO/ETA (Stephanie Bush-Goddard@nrc.gov)

OEMail Resource

ROP Reports

File located: R:\_REACTORS\_GG\GG 2011002 RP-RLS-vgg.docx

SUNSI Rev Compl. Yes No ADAMS Yes No Reviewer Initials VGG

Publicly Avail Yes No Sensitive Yes No Sens. Type Initials VGG

SRI:DRP/PBC SPE:DRP/PBC C:DRS/EB1 C:DRS/EB2

RLSmith BHagar TRFarnholtz NFOKeefe

/RA/RCHagar for /RA/ /RA/ /RA/

5/4/2011 5/4/2011 4/21/2011 4/15/2011

C:DRS/OB C:TSS C:DRS/PSB1 C:DRS/PSB2 C:ACES/SAC

MHaire MHay MPShannon GEWerner NTaylor

/RA/ /RA/ /RA/ /RA/ /RA/

4/15/2011 4/18/2011 4/18/2011 4/15/2011 4/18/2011

C:DRP/C

VGaddy

/RA/

5/10/11

OFFICIAL RECORD COPY T=Telephone E=E-mail F=Fax

U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

Docket: 05000416

License: NPF-29

Report: 05000416/2011002

Licensee: Entergy Operations, Inc.

Facility: Grand Gulf Nuclear Station

Location: 7003 Baldhill Road

Port Gibson, MS 39150

Dates: January 21, 2011, through March 27, 2011

Inspectors: R. Smith, Senior Resident Inspector

M. Baquera, Resident Inspector, Palo Verde

A. Fairbanks, Reactor Inspector

C. Graves, Health Physicist

L. Ricketson, P.E., Senior Health Physicist

E. Uribe, Reactor Inspector

Approved By: Vincent Gaddy, Chief, Project Branch C

Division of Reactor Projects

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SUMMARY OF FINDINGS

IR 05000416/2011002; 1/1/2011 - 3/27/2011; Grand Gulf Nuclear Station, Integrated Resident

and Regional Report; Fire Protection, Maintenance Effectiveness, Radiological Hazard

Assessment and Exposure Controls, and Event Follow-Up.

The report covered a 3-month period of inspection by resident inspectors and an announced

baseline inspection by region-based inspectors. Five Green noncited violations of significance

were identified and one Green finding of significance was identified. The significance of most

findings is indicated by their color (Green, White, Yellow, or Red) using Inspection Manual

Chapter 0609, Significance Determination Process. The cross-cutting aspect is determined

using Inspection Manual Chapter 0310, Components Within the Cross Cutting Areas. Findings

for which the significance determination process does not apply may be Green or be assigned a

severity level after NRC management review. The NRC's program for overseeing the safe

operation of commercial nuclear power reactors is described in NUREG-1649, Reactor

Oversight Process, Revision 4, dated December 2006.

A. NRC-Identified Findings and Self-Revealing Findings

Cornerstone: Mitigating Systems

requires the final safety analysis report be updated, at intervals not exceeding 24

months, to reflect changes made in the facility or procedures described in the

final safety analysis report. Licensee personnel failed to update the original

revision of the final safety analysis report to reflect the actual number of low

pressure coolant injection loops available for automatic initiation during shutdown

cooling operations in Mode 3. The licensee plans to update the final safety

analysis report at the next scheduled revision. This finding was entered into the

licensees corrective action program as condition report CR-GGN-2011-01631.

The failure of licensing personnel to update the final safety analysis report to

reflect the available low pressure coolant injection loops for automatic initiation

during shutdown cooling operations in Mode 3 was a performance deficiency.

This finding was evaluated using traditional enforcement because it had the

potential for impacting the NRCs ability to perform its regulatory function. The

inspectors used the NRC Enforcement Policy, dated September 30, 2010, to

evaluate the significance of this violation. Consistent with the NRC Enforcement

Policy, this finding was determined to be a Severity Level IV noncited violation.

for the licensees failure to demonstrate that the performance of the train B

control room air conditioner was being effectively controlled through the

performance of appropriate preventive maintenance. Engineering did not

properly evaluate maintenance rule functional failures resulting in the system

remaining in an a(2) status instead of an a(1) status. As corrective action, the

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train B control room air conditioner was moved into an a(1) status. The licensee

entered this issue into their corrective action program as Condition Report

CR-GGN-2011-01623.

The finding was more than minor because it was associated with the equipment

performance attribute of the Mitigating Systems Cornerstone and adversely

affected the cornerstone objective to ensure the availability, reliability, and

capability of systems that respond to initiating events to prevent undesirable

consequences. Inspectors performed a Phase 1 screening, in accordance with

Inspection Manual Chapter 0609, Attachment 4, Phase 1 - Initial Screening and

Characterization of Findings, and determined that the finding was of very low

safety significance (Green) because the maintenance rule aspect of the finding

did not cause an actual loss of safety function of the system nor did it cause a

component to be inoperable. As corrective action, the train B control room air

conditioner was moved into an (a)(1) status. This finding had a crosscutting

aspect in the area of human performance associated with the decision making

component because licensee personnel failed to make appropriate safety-

significant or risk-significant decisions to address the multiple failures of the train

B control room air conditioner compressor. H.1(a) (Section 1R12.b.2)

  • Green. The inspectors reviewed a self-revealing noncited violation of 10 CFR

Part 50, Appendix B, Criterion XVI, Corrective Action, after the licensee failed to

determine the cause and prevent recurrence of a significant condition adverse to

quality associated with the train B control room air conditioner compressor

tripping due to low oil pressure. Specifically, on December 13, 2010, the train B

control room air conditioner compressor tripped on low oil pressure after the

licensee had performed a root cause analysis to identify the cause and prevent

recurrence of a similar compressor trip on October 14, 2010. As immediate

corrective action, the licensee installed an inline suction filter. No additional

failures have occurred since its installation. The finding was entered into the

licensees corrective action program as Condition Report CR-GGN-2010-07315.

This finding was more than minor because it was associated with the equipment

performance attribute of the Mitigating Systems Cornerstone and adversely

affected the cornerstone objective to ensure the availability, reliability, and

capability of systems that respond to initiating events to prevent undesirable

consequences. Using Inspection Manual Chapter 0609, "Significance

Determination Process," Phase 1 worksheets, the inspectors determined that a

Phase 2 analysis was required because the finding represented a loss of system

safety function. The plant-specific risk informed notebook does not include the

evaluation of risk caused by the loss of cooling to the main control room.

Therefore, the senior reactor analyst conducted a Phase 3 analysis. Based on

the bounding analysis, the analyst determined that the change in core damage

frequency result was 5.9 x 10-7. This noncited violation was therefore determined

to be of very low safety significance (Green). This finding had a crosscutting

aspect in the area of problem identification and resolution associated with the

corrective action program component because licensee personnel failed to

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thoroughly evaluate the multiple failures of the train B control room air conditioner

compressor. P.1(c) (Section 4OA3.1.b)

Cornerstone: Barrier Integrity

  • Green. The inspectors identified a noncited violation of Facility Operating License

Condition 2.C(41), involving the failure to ensure that transient combustible were

not stored in the fire exclusion zone near the independent spent fuel storage

installation. The inspectors performed a quarterly fire protection inspection of

independent spent fuel storage installation and identified a large air conditioner

with combustible material covering it located in the fire exclusion zone that was

within 60 feet of the dry fuel storage pad. The inspectors determined through

interviews that the material had been placed there the previous day by the

maintenance department. As immediate corrective action the licensee removed

the combustible material from the area. The finding was entered into the

licensees corrective action program as Condition Report CR-GGN-2011-00455.

This finding was more than minor because it was associated human performance

attribute of the Barrier Integrity Cornerstone to provide reasonable assurance

that physical design barriers protect the public from radionuclide releases caused

by accidents or events. Using Manual Chapter 0609, Appendix F, Fire

Protection Significance Determination Process, the inspectors determined that

the finding impacted the fire prevention and administrative controls category.

The inspectors assigned a low degradation rating due to the fact that the amount

of combustible material in the area was minimal. The inspectors concluded that

the finding was of very low safety significance (Green) due to the fact there were

no fire ignition sources in the area. The cause of this finding has a crosscutting

aspect in the area of human performance associated with the work practices

component because the licensee failed to effectively communicate expectations

regarding storage of combustible material near the dry fuel storage pad. H.4(b)

(Section 1R05.1.b)

  • Green. The inspectors reviewed a self-revealing, Green finding of EN-DC-115,

Engineering Change Process, involving the failure to maintain adequate design

control measures associated with the installation of the mitigation monitoring

system. On November 8, 2010, a reactor coolant pressure boundary failure

occurred at the skid mounted Online Noble Chemical - Mitigation Monitoring

System pump inside primary containment. The positive displacement sample

pump ejected the pump piston from the housing, resulting in an approximate

7 gpm leak of reactor coolant. The steam leak resulted in a reactor recirculation

system flow control valve lockup (due to hydraulic power unit motor failure) and

approximately 15,000 square feet of contaminated area in the primary

containment structure. The licensee failed to ensure proper validation testing for

the pump prior to installation. Specifically, the licensee did not ensure that the

pump could withstand the operating pressures and temperatures of the system in

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which it was installed. The licensee removed the mitigation monitoring system

from service and isolated the skid from the reactor water cleanup system. This

finding was entered into the licensees corrective action program as Condition

Report CR-GGN-2010-07852.

The finding is more than minor because it affects the design control attribute of

the Barrier Integrity Cornerstone to provide reasonable assurance that physical

design barriers protect the public from radionuclide releases caused by accidents

or events. Therefore, using inspection Manual Chapter 0609, "Significance

Determination Process," Phase 1 Worksheet for LOCA initiators, the inspectors

concluded that the finding was of very low safety significance (Green) because

the failure of the mitigation monitoring system would not have exceeded technical

specifications limits for identified leakage in the reactor coolant system. This

finding has a crosscutting aspect in the work practices component of the human

performance area; because the licensee failed to adequately oversee the design

of the mitigation monitoring system such that nuclear safety is supported. H.4(c)

(Section 4OA3.2.b)

Cornerstone: Occupational Radiation Safety

  • Green. The inspectors identified a noncited violation of Technical Specification 5.7.2, resulting from the licensees failure to use a qualified radiation protection

technician to provide direct continuous coverage of work in a locked high

radiation area. The finding was placed into the corrective action program as

Condition Report CR-GGN-2011-01045, and corrective action was being

evaluated.

The failure to use a qualified radiation protection technician to provide direct

continuous coverage of work in a locked high radiation area is a performance

deficiency. The finding was more than minor because it was associated with the

Occupational Radiation Safety Cornerstone attribute (exposure control) of

program and process and affected the cornerstone objective, in that, the failure

to use qualified radiation protection technicians to provide job coverage in a high

radiation area with dose rates in excess of 1000 mrem/hr had the potential to

increase personnel dose. Using the Occupational Radiation Safety Significance

Determination Process, the inspectors determined the finding to have very low

safety significance because: (1) it was not associated with ALARA planning or

work controls, (2) there was no overexposure, (3) there was no substantial

potential for an overexposure, and (4) the ability to assess dose was not

compromised. (Section 2RS01.b)

B. Licensee-Identified Violations

Violations of very low safety significance, which were identified by the licensee, have

been reviewed by the inspectors. Corrective actions taken or planned by the licensee

have been entered into the licensees corrective action program. These violations and

corrective action tracking numbers (condition report numbers) are listed in

Section 4OA7.

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REPORT DETAILS

Summary of Plant Status

Grand Gulf Nuclear Station began the inspection period at full rated thermal power. On January

9, 2011, operators reduced power to 68 percent for a planned control rod sequence exchange

and isolation of the moisture separator reheaters (MSRs) second stage steam to both the A

and B MSRs due to tube leaks in the A MSR. The plant was returned to 96 percent power on

January 10, 2011, which was maximum power level allowed with MSR second stage steam

isolated. On February 18, 2011, operators reduced power to 77 percent for monthly control rod

testing, turbine testing, and to remove B heater drain pump from service in an attempt to repair

a steam leak on the heater drain pump B discharge flange. The plant was returned to 96

percent power on February 19, 2011. On March 11, 2011, operators reduced power to 84

percent power for a planned control rod testing and to remove B heater drain pump from

service in another attempt to repair a steam leak on the heater drain pump B discharge flange.

The plant was returned to 96 percent power on March 12, 2011. On March 23, 2011, operators

reduced power to 93 percent power to remove the B heater drain pump from service again in

another attempt to repair a steam leak on the heater drain pump B pump discharge flange.

The plant was returned to 96 percent power on March 12, 2011. The plant remained at 96

percent power for the remainder of the inspection period.

1. REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity, and

Emergency Preparedness

1R01 Adverse Weather Protection (71111.01)

.1 Readiness for Seasonal Extreme Weather Conditions

a. Inspection Scope

The inspectors performed a review of the adverse weather procedures for seasonal

extreme low temperatures. The inspectors verified that weather-related equipment

deficiencies identified during the previous year were corrected prior to the onset of

seasonal extremes, and evaluated the implementation of the adverse weather

preparation procedures and compensatory measures for the affected conditions before

the onset of, and during, the adverse weather conditions.

During the inspection, the inspectors focused on plant-specific design features and the

procedures used by plant personnel to mitigate or respond to adverse weather

conditions. Additionally, the inspectors reviewed the updated final safety analysis report

and performance requirements for systems selected for inspection and verified that

operator actions were appropriate as specified by plant-specific procedures. Specific

documents reviewed during this inspection are listed in the attachment. The inspectors

also reviewed corrective action program items to verify that plant personnel were

identifying adverse weather issues at an appropriate threshold and entering them into

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their corrective action program in accordance with station corrective action procedures.

The inspectors reviews focused specifically on the following plant systems:

  • Fire water pumps and tanks

These activities constitute completion of one readiness for seasonal adverse weather

sample as defined in Inspection Procedure 71111.01-05.

b. Findings

No findings were identified.

.2 Readiness for Impending Adverse Weather Conditions

a. Inspection Scope

Since extreme cold conditions and icing were forecast in the vicinity of the facility for

January 9, 2011, the inspectors reviewed overall preparations/protection for the

expected weather conditions. On January 7, 2011, the inspectors inspected the standby

service water towers because their safety-related functions could be affected as a result

of the extreme cold and icing conditions forecast for the facility. The inspectors observed

space heater operation and weatherized enclosures to ensure operability of affected

systems. The inspectors reviewed licensee procedures and discussed potential

compensatory measures with control room personnel. The inspectors focused on plant

managements actions for implementing the stations procedures for ensuring adequate

personnel for safe plant operation and emergency response would be available.

Specific documents reviewed during this inspection are listed in the attachment.

These activities constitute completion of one readiness for impending adverse weather

condition sample as defined in Inspection Procedure 71111.01-05.

b. Findings

No findings were identified.

1R04 Equipment Alignments (71111.04)

.1 Partial Walkdown

a. Inspection Scope

The inspectors performed partial system walkdowns of the following risk-significant

systems:

  • Division II standby service water system during Division I maintenance outage

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maintenance outage

maintenance outage

  • Division II standby diesel generator system during Division I maintenance outage

maintenance outage

The inspectors selected these systems based on their risk significance relative to the

reactor safety cornerstones at the time they were inspected. The inspectors attempted

to identify any discrepancies that could affect the function of the system, and, therefore,

potentially increase risk. The inspectors reviewed applicable operating procedures,

system diagrams, UFSAR, technical specification requirements, administrative technical

specifications, outstanding work orders, condition reports, and the impact of ongoing

work activities on redundant trains of equipment in order to identify conditions that could

have rendered the systems incapable of performing their intended functions. The

inspectors also inspected accessible portions of the systems to verify system

components and support equipment were aligned correctly and operable. The

inspectors examined the material condition of the components and observed operating

parameters of equipment to verify that there were no obvious deficiencies. The

inspectors also verified that the licensee had properly identified and resolved equipment

alignment problems that could cause initiating events or impact the capability of

mitigating systems or barriers and entered them into the corrective action program with

the appropriate significance characterization. Specific documents reviewed during this

inspection are listed in the attachment.

These activities constitute completion of five partial system walkdown samples as

defined in Inspection Procedure 71111.04-05.

b. Findings

No findings were identified.

1R05 Fire Protection (71111.05)

Quarterly Fire Inspection Tours

a. Inspection Scope

The inspectors conducted fire protection walkdowns that were focused on availability,

accessibility, and the condition of firefighting equipment in the following risk-significant

plant areas:

  • Division II diesel generator room (1D303)

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  • Reactor Core Isolation Pump Room (1A104)
  • Dry fuel storage pad area (Area 59 the Yard)

The inspectors reviewed areas to assess if licensee personnel had implemented a fire

protection program that adequately controlled combustibles and ignition sources within

the plant; effectively maintained fire detection and suppression capability; maintained

passive fire protection features in good material condition; and had implemented

adequate compensatory measures for out of service, degraded or inoperable fire

protection equipment, systems, or features, in accordance with the licensees fire plan.

The inspectors selected fire areas based on their overall contribution to internal fire risk

as documented in the plants Individual Plant Examination of External Events with later

additional insights, their potential to affect equipment that could initiate or mitigate a

plant transient, or their impact on the plants ability to respond to a security event. Using

the documents listed in the attachment, the inspectors verified that fire hoses and

extinguishers were in their designated locations and available for immediate use; that

fire detectors and sprinklers were unobstructed; that transient material loading was

within the analyzed limits; and fire doors, dampers, and penetration seals appeared to

be in satisfactory condition. The inspectors also verified that minor issues identified

during the inspection were entered into the licensees corrective action program.

Specific documents reviewed during this inspection are listed in the attachment.

These activities constitute completion of five quarterly fire-protection inspection samples

as defined in Inspection Procedure 71111.05-05.

b. Findings

Introduction. The inspectors identified a Green noncited violation of Facility Operating

License Condition 2.C(41), involving the failure to ensure that transient combustible were

not stored in the fire exclusion zone near the independent spent fuel storage installation.

Description. On January 24, 2011, the inspectors performed a quarterly fire protection

inspection of independent spent fuel storage installation. The inspectors identified a

large air conditioner with combustible material covering it located in the fire exclusion

zone that appeared to be within 60 feet of the dry fuel storage pad. The inspectors

brought this to the attention of the work center senior reactor operator. The work center

senior reactor operator contacted the site fire engineer, who walked down the fire

exclusion zone and determined that the combustible material covering the air conditioner

was within the 60 feet of the dry fuel storage pad, which is in violation of plant procedural

requirements. The inspectors determined through interviews that the material had been

placed there the day before by the maintenance department. The site had the air

conditioner and the covering material removed from the fire exclusion zone to restore

compliance.

The licensee documented this violation in Condition Report CR-GGN-2011-00455. Its

short-term corrective actions included removing the combustible material from the area.

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Analysis. The inspectors determined that the failure to follow fire protection procedures

developed for control of transient combustible material stored near the dry spent fuel

storage pad was a performance deficiency. This finding was more than minor because it

was associated human performance attribute of the Barrier Integrity Cornerstone to

provide reasonable assurance that physical design barriers protect the public from

radionuclide releases caused by accidents or events. Using Manual Chapter 0609,

Appendix F, Fire Protection Significance Determination Process, the inspectors

determined that the finding impacted the fire prevention and administrative controls

category. The inspectors assigned a low degradation rating due to the fact that the

amount of combustible material in the area was minimal. The inspectors concluded that

the finding was of very low safety significance (Green) due to the fact there were no fire

ignition sources in the area. The finding has a crosscutting aspect in the area of human

performance associated with the work practices component because the licensee failed

to effectively communicate expectations regarding storage of combustible material near

the dry fuel storage pad. H.4(b)

Enforcement. Grand Gulf Nuclear Station Facility Operating License Condition 2.C(41)

states, in part, that the plant shall implement and maintain in effect all provisions of the

Fire Protection Program as described in the UFSAR. UFSAR Section 9B,

Administrative Controls, section 9B.6.a, governs the handling and limits the use of

ordinary combustible materials in safety related areas. Fire area 59, defined as the yard,

contains the fire exclusion area next to the dry fuel storage pad and prohibits the storage

of any combustible material in this area. Contrary to this, on January 23, 2011, the

licensee stored combustible material inside the transient combustible exclusion zone

near the dry fuel storage pad. The licensee restored compliance by removing the

material from the area on January 25, 2011. Because the finding was of very low safety

significance (Green) and was documented in the licensees corrective action program as

CR-GGN-2011-0455, this finding is being treated as a noncited violation (NCV)

consistent with Section VI.A of the NRC Enforcement Policy:

NCV 05000416/2011002-01; Transient Combustible Stored in the Fire Exclusion Zone

Near the Independent Spent Fuel Storage Installation.

1R06 Flood Protection Measures (71111.06)

a. Inspection Scope

The inspectors reviewed the flooding analysis, and plant procedures to assess seasonal

susceptibilities involving internal flooding; reviewed the Updated Final Safety Analysis

Report and corrective action program to determine if licensee personnel identified and

corrected flooding problems; inspected underground bunkers/manholes to verify the

adequacy of sump pumps, level alarm circuits, cable splices subject to submergence,

and drainage for bunkers/manholes; subject to flooding that contain cables whose failure

could disable risk-significant equipment. The inspectors walked down the areas listed

below. Specific documents reviewed during this inspection are listed in the attachment.

  • January 11, 2011, division 1 and 2 standby service water manholes

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These activities constitute completion of one bunker/manhole sample as defined in

Inspection Procedure 71111.06-05.

b. Findings

No findings were identified.

1R07 Heat Sink Performance (71111.07)

a. Inspection Scope

The inspectors reviewed licensee programs, verified performance against industry

standards, and reviewed critical operating parameters and maintenance records for the

Division 1 emergency diesel generator jacket water and lube oil heat exchangers. The

inspectors verified that performance tests were satisfactorily conducted for heat

exchangers/heat sinks and reviewed for problems or errors; the licensee utilized the

periodic maintenance method outlined in EPRI Report NP 7552, Heat Exchanger

Performance Monitoring Guidelines; the licensee properly utilized biofouling controls;

the licensees heat exchanger inspections adequately assessed the state of cleanliness

of their tubes; and the heat exchanger was correctly categorized under 10 CFR 50.65,

Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power

Plants. Specific documents reviewed during this inspection are listed in the attachment.

These activities constitute completion of one heat sink inspection sample as defined in

Inspection Procedure 71111.07-05.

b. Findings

No findings were identified.

1R11 Licensed Operator Requalification Program (71111.11)

a. Inspection Scope

On January 31, 2011, the inspectors observed a crew of licensed operators in the plants

simulator to verify that operator performance was adequate, evaluators were identifying

and documenting crew performance problems and training was being conducted in

accordance with licensee procedures. The inspectors evaluated the following areas:

  • Licensed operator performance
  • Crews clarity and formality of communications
  • Crews ability to take timely actions in the conservative direction
  • Crews prioritization, interpretation, and verification of annunciator alarms
  • Crews correct use and implementation of abnormal and emergency procedures

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  • Control board manipulations
  • Oversight and direction from supervisors
  • Crews ability to identify and implement appropriate technical specification

actions and emergency plan actions and notifications

The inspectors compared the crews performance in these areas to preestablished

operator action expectations and successful critical task completion requirements.

Specific documents reviewed during this inspection are listed in the attachment.

These activities constitute completion of one quarterly licensed-operator requalification

program sample as defined in Inspection Procedure 71111.11.

b. Findings

No findings were identified.

1R12 Maintenance Effectiveness (71111.12)

a. Inspection Scope

The inspectors evaluated degraded performance issues involving the following risk

significant systems:

  • Control room air conditioning (Z51)

The inspectors reviewed events such as where ineffective equipment maintenance has

resulted in valid or invalid automatic actuations of engineered safeguards systems and

independently verified the licensee's actions to address system performance or condition

problems in terms of the following:

  • Implementing appropriate work practices
  • Identifying and addressing common cause failures
  • Characterizing system reliability issues for performance
  • Charging unavailability for performance
  • Trending key parameters for condition monitoring

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  • Verifying appropriate performance criteria for structures, systems, and

components classified as having an adequate demonstration of performance

through preventive maintenance, as described in 10 CFR 50.65(a)(2), or as

requiring the establishment of appropriate and adequate goals and corrective

actions for systems classified as not having adequate performance, as described

in 10 CFR 50.65(a)(1)

The inspectors assessed performance issues with respect to the reliability, availability,

and condition monitoring of the system. In addition, the inspectors verified maintenance

effectiveness issues were entered into the corrective action program with the appropriate

significance characterization. Specific documents reviewed during this inspection are

listed in the attachment.

These activities constitute completion of three quarterly maintenance effectiveness

samples as defined in Inspection Procedure 71111.12-05.

b. Findings

.1 Failure to Update Available Low Pressure Cooling Injection Loops in the Updated Final

Safety Analysis Report

Introduction. Inspectors identified a Severity Level IV, noncited violation for the

licensees failure to update the final (updated) safety analysis report in accordance with

10 CFR 50.71(e)(4). Specifically, the licensee failed to update Section 6.3, Emergency

Core Cooling Systems, to appropriately reflect the available emergency core cooling

equipment during shutdown cooling operations in Mode 3.

Description. On February 28, 2011, while reviewing the updated final safety analysis

report for a maintenance effectiveness inspection of the residual heat removal system,

the inspectors determined that Section 6.3.1.1.1.e, Emergency Core Cooling Systems,

states, The ECCS is designed to satisfy all criteria specified in Section 6.3 for any

normal mode of reactor operation. Additionally, Section 6.3.1.1.2.d states, In the event

of a break in a pipe that is part of the reactor coolant pressure boundary, no single active

component failure in the emergency core cooling system shall prevent automatic

initiation and successful operation of less than the following combination of emergency

core cooling system equipment: 1) Three low pressure coolant injection loops, the low

pressure core spray and the automatic depressurization system (i.e., high pressure core

spray failure); 2) Two low pressure coolant injection loops, the high pressure core spray

and the automatic depressurization system (i.e., low pressure core spray diesel

generator failure); and 3) One low pressure coolant injection loop, the low pressure core

spray, the high pressure core spray and automatic depressurization system (i.e., low

pressure coolant injection diesel generator failure).

Procedure 03-1-01-3, Plant Shutdown, Revision 118, Section 6.14 states, When

shutdown cooling is placed in service at less than 135 psig, then the associated

containment spray and low pressure coolant injection systems may be considered

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operable if capable of being manually realigned and not otherwise inoperable.

Inspectors noted that because the residual heat removal system that provides shutdown

cooling in Mode 3 is not available for automatic initiation (must be manually realigned) of

low pressure coolant injection, in the event of a reactor coolant system pipe break, that

the aforementioned statements in Section 6.3 did not appropriately reflect the available

emergency core cooling equipment during shutdown cooling operations. In other words,

the combinations of emergency core cooling equipment available for automatic initiation

would include one less low pressure coolant injection loop.

The licensee entered this issue into their corrective actions program as Condition Report

CR-GGN-2011-01631. The licensee planned to take actions to update the updated final

safety analysis report at the next scheduled revision.

Analysis. The failure of licensing personnel to update the final safety analysis report to

reflect the available low pressure coolant injection loops for automatic initiation during

shutdown cooling operations in Mode 3 was a performance deficiency. This finding was

evaluated using traditional enforcement because it had the potential for impacting the

NRCs ability to perform its regulatory function. The inspectors used the NRC

Enforcement Policy, dated September 30, 2010, to evaluate the significance of this

violation. Consistent with the NRC Enforcement Policy, this finding was determined to

be a Severity Level IV noncited violation. This finding had no crosscutting aspect as it

was associated with a traditional enforcement violation.

Enforcement. Title 10 CFR 50.71(e)(4) requires the final safety analysis report be

updated, at intervals not exceeding 24 months, and states in part, the revisions must

reflect all changes made in the facility or procedures described in the FSAR. Contrary

to the above, licensing personnel failed to update the original revision of the final safety

analysis report to reflect the actual number of low pressure coolant injection loops

available for automatic initiation during shutdown cooling operations in Mode 3.

Because the finding is of very low safety significance and has been entered into the

corrective action program as Condition Report CR-GGN-2011-01631, this violation is

being treated as a noncited violation consistent with the NRC Enforcement Policy:

NCV 0500416/20011002-02, "Failure to Update Available Low Pressure Coolant

Injection Loops in the Updated Final Safety Analysis Report."

.2 Failure to Demonstrate Maintenance Effectiveness of Train B Control Room Air

Conditioner

Introduction. The inspectors identified a Green noncited violation of 10 CFR Part

50.65(a)(2) for the failure to demonstrate that the performance of the train B control

room air conditioner was being effectively controlled through the performance of

appropriate preventive maintenance.

Description. On March 2, 2011, the inspectors performed a maintenance effectiveness

inspection of the control room air conditioning system. Inspectors determined that on

February 3, 2010, the train B control room air conditioner compressor was replaced with

a remanufactured compressor as part of annual preventative maintenance of the

system. On March 27, 2010, the control room air conditioner compressor tripped on low

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usable oil pressure. The licensees investigation revealed that the compressor pencil

strainer was approximately fifty percent covered with unidentified contaminants. Similar

contaminants were identified on the oil sump strainer. The licensee concluded that the

compressor had been installed with contaminants inside the lower half of the

compressor, and subsequently replaced the remanufactured compressor on April 1,

2010, with a newly rebuilt compressor. System engineering did not classify this event as

a maintenance rule functional failure even though operations had declared the train

inoperable and also stated in their operability determination that it could not meet its 30

day mission time.

The train B control room air conditioner compressor subsequently either tripped or failed

to properly cool the control room, due to low usable oil pressure, on three separate

occasions (once in April, once May, and once in June). In response to the June failure,

the licensee performed extensive maintenance on the train B control room air

conditioner compressor, which included installing a five micron suction line filter in the

system. Additionally, all three events were identified as maintenance rule functional

failures attributed to foreign material fouling in the system, which would have resulted in

the performance criteria being exceeded (less than or equal to two maintenance rule

functional failure events or as a repeat functional failure). However, the sites

maintenance rule coordinator informed the inspectors that the first two events in April

and May were not counted toward the criteria because they were from the same cause

as the June event and; therefore, they would all be counted as one failure even thought

the train was returned to service each time after corrective maintenance was performed

and declared operable by operations. Additionally, on June 22, 2010, the train was

declared inoperable due to multiple Freon leaks and was classified as another

maintenance rule functional failure for the train. On August 10, 2010, the licensee

performed a Maintenance Rule (a)(1) evaluation for the subject system and, based on

the presentation to the expert panel by system engineering, the panel only considered

two events as maintenance rule functional failures. System engineering did not count

the one failure in March or consider the two failures in April or May. The expert panel

only considered the failures in June due to low oil pressure and Freon leaks. Therefore

the expert panel concluded that, although the train B control room air conditioner system

had exceeded its established performance criteria for functional failure events, a number

of effective corrective actions had been identified and implemented and additional

corrective actions were not necessary; therefore, the subject system was allowed to

retain its (a)(2) status.

The train B control room air conditioner compressor subsequently either tripped or failed

to properly cool the control room, due to low usable oil pressure, on two separate

occasions (once in September and once in October). The October trip of the subject

system compressor occurred while the train A control room air conditioner was out of

service for routine maintenance. The compressor pencil strainer and sump strainer were

again identified with contaminants on them. The licensee was required to make an

eight-hour report to the NRC and submit a licensee event report due to both trains of

control room air conditioner being inoperable. The licensees root cause analysis failed

to identify that the train B control room air conditioner performance had not been

demonstrated through the performance of appropriate preventative maintenance; nor did

the root cause identify that the licensee failed to set goals and monitor the system as

- 15 - Enclosure

required by 10 CFR 50.65(a)(1). The train B control room air conditioner was ultimately

moved into (a)(1) status on February 4, 2011, after the subject compressor again tripped

due to low oil pressure on December 13, 2010. After this trip and upon further

evaluation, the licensee performed an additional corrective action that installed an in line

suction filter with smaller filtering diameter and larger surface area to remove foreign

material from the system. They also modified the operator rounds to obtain daily

readings of differential pressure across this new filter and through calculation,

determined a differential pressure necessary for the filter to be changed out and the unit

to be inspected for foreign materials.

The licensee entered this issue into their corrective actions program as Condition Report

CR-GGN-2011-01623. From installation of the new inline suction filter to the conclusion

of the inspection period, no additional trips of train B control room air conditioning have

occurred.

Analysis. The inspectors determined that the failure to demonstrate that the

performance of the train B control room air conditioner was being effectively controlled

through the performance of appropriate preventive maintenance was a performance

deficiency. The finding was more than minor because it was associated with the

equipment performance attribute of the Mitigating Systems Cornerstone and adversely

affected the cornerstone objective to ensure the availability, reliability, and capability of

systems that respond to initiating events to prevent undesirable consequences.

Inspectors performed a Phase 1 screening, in accordance with Inspection Manual

Chapter 0609, Attachment 4, Phase 1 - Initial Screening and Characterization of

Findings, and determined that the finding was of very low safety significance (Green)

because it did not result in a loss of system safety function since the train A control room

air conditioner remained operable. This finding had a crosscutting aspect in the area of

human performance associated with the decision making component because licensee

personnel failed to make appropriate safety-significant or risk-significant decisions to

address the multiple failures of the train B CRAC compressor. H.1(a)

Enforcement. Title 10 CFR 50.65(a)(2), states, in part, that monitoring as specified in

paragraph (a)(1) of this section is not required where it has been demonstrated that the

performance or condition of a structure, system, or component is being effectively

controlled through the performance of appropriate preventative maintenance, such that

the structure, system, or component remains capable of performing its intended

function. Contrary to the above, from March 2010 to February 2011, the licensee failed

to demonstrate that the performance of the train B control room air conditioning system

was effectively controlled through the performance of appropriate preventative

maintenance. This finding was entered into the licensees corrective action program as

Condition Report CR-GGN-2011-01623. Because this finding was determined to be of

very low safety significance and was entered into the licensees corrective action

program, this violation is being treated as a noncited violation consistent with the NRC

Enforcement Policy: NCV 05000285/2011002-03, Failure to Demonstrate Maintenance

Effectiveness of Train B Control Room Air Conditioner.

- 16 - Enclosure

1R13 Maintenance Risk Assessments and Emergent Work Control (71111.13)

a. Inspection Scope

The inspectors reviewed licensee personnel's evaluation and management of plant risk

for the maintenance and emergent work activities affecting risk-significant and safety-

related equipment listed below to verify that the appropriate risk assessments were

performed prior to removing equipment for work:

  • On January 9, 2011, during an ice storm requiring the plant to enter a yellow risk

condition and enter their off normal event procedure for severe weather.

  • On February 3, 2011, during an ice storm requiring the plant to enter a yellow risk

condition and enter their off normal event procedure for severe weather. The

weather required the site to cancel work and monitor their safety related standby

service water system for icing conditions.

  • On February 9, 2011, during a winter storm, while a divisions 1 diesel generator

and residual heat removal A were out for planned maintenance outage requiring

the plant to enter orange risk.

  • On February 28, 2011, during the accidental unearthing of energized plant

service water pump cables, no consequence to the plant but resulted in work

stoppage and evaluation of risk status for the site.

  • On March 8-9, 2011, with an emergent issue with the division 1 diesel generator

and a tornado watch issued for the area requiring the plant to enter yellow risk.

The site entered their severe weather off normal procedure; this procedure

required the site to secure from half scram surveillances.

The inspectors selected these activities based on potential risk significance relative to

the reactor safety cornerstones. As applicable for each activity, the inspectors verified

that licensee personnel performed risk assessments as required by 10 CFR 50.65(a)(4)

and that the assessments were accurate and complete. When licensee personnel

performed emergent work, the inspectors verified that the licensee personnel promptly

assessed and managed plant risk. The inspectors reviewed the scope of maintenance

work, discussed the results of the assessment with the licensee's probabilistic risk

analyst or shift technical advisor, and verified plant conditions were consistent with the

risk assessment. The inspectors also reviewed the technical specification requirements

and inspected portions of redundant safety systems, when applicable, to verify risk

analysis assumptions were valid and applicable requirements were met. Specific

documents reviewed during this inspection are listed in the attachment.

These activities constitute completion of five emergent work control inspection samples

as defined in Inspection Procedure 71111.13-05.

- 17 - Enclosure

b. Findings

No findings were identified.

1R15 Operability Evaluations (71111.15)

a. Inspection Scope

The inspectors reviewed the following issues:

switch fluctuating

  • Train A standby service water drift eliminator support base plate corrosion and

missing brass bolts

temperature switch

  • Division 1 diesel generator auxiliary oil pump not obtaining procedural pressures

during pre-lube prior to surveillance run

The inspectors selected these potential operability issues based on the risk significance

of the associated components and systems. The inspectors evaluated the technical

adequacy of the evaluations to ensure that technical specification operability was

properly justified and the subject component or system remained available such that no

unrecognized increase in risk occurred. The inspectors compared the operability and

design criteria in the appropriate sections of the technical specifications and UFSAR to

the licensee personnels evaluations to determine whether the components or systems

were operable. Where compensatory measures were required to maintain operability,

the inspectors determined whether the measures in place would function as intended

and were properly controlled. The inspectors determined, where appropriate,

compliance with bounding limitations associated with the evaluations. Additionally, the

inspectors also reviewed a sampling of corrective action documents to verify that the

licensee was identifying and correcting any deficiencies associated with operability

evaluations. Specific documents reviewed during this inspection are listed in the

attachment.

These activities constitute completion of six operability evaluations inspection samples

as defined in Inspection Procedure 71111.15-04

- 18 - Enclosure

b. Findings

No findings were identified.

1R18 Plant Modifications (71111.18)

a. Inspection Scope

To verify that the safety functions of important safety systems were not degraded, the

inspectors reviewed the following temporary modifications:

Sensor (EC22768)

The inspectors reviewed the temporary modifications and the associated safety-

evaluation screening against the system design bases documentation, including the

updated final safety analysis report and the technical specifications, and verified that the

modification did not adversely affect the system operability/availability. The inspectors

also verified that the installation and restoration were consistent with the modification

documents and that configuration control was adequate. Additionally, the inspectors

verified that the temporary modification was identified on control room drawings,

appropriate tags were placed on the affected equipment, and licensee personnel

evaluated the combined effects on mitigating systems and the integrity of radiological

barriers.

These activities constitute completion of two samples for temporary plant modifications

as defined in Inspection Procedure 71111.18-05.

b. Findings

No findings were identified.

1R19 Postmaintenance Testing (71111.19)

a. Inspection Scope

The inspectors reviewed the following postmaintenance activities to verify that

procedures and test activities were adequate to ensure system operability and functional

capability:

  • For standby liquid B after a maintenance outage
  • For reactor protection motor generator B after required maintenance

- 19 - Enclosure

  • For division 1 diesel generator after a maintenance outage

maintenance

The inspectors selected these activities based upon the structure, system, or

component's ability to affect risk. The inspectors evaluated these activities for the

following (as applicable):

  • The effect of testing on the plant had been adequately addressed; testing was

adequate for the maintenance performed

  • Acceptance criteria were clear and demonstrated operational readiness; test

instrumentation was appropriate

The inspectors evaluated the activities against the technical specifications, the UFSAR,

10 CFR Part 50 requirements, licensee procedures, and various NRC generic

communications to ensure that the test results adequately ensured that the equipment

met the licensing basis and design requirements. In addition, the inspectors reviewed

corrective action documents associated with postmaintenance tests to determine

whether the licensee was identifying problems and entering them in the corrective action

program and that the problems were being corrected commensurate with their

importance to safety. Specific documents reviewed during this inspection are listed in

the attachment.

These activities constitute completion of six postmaintenance testing inspection samples

as defined in Inspection Procedure 71111.19-05.

b. Findings

No findings were identified.

1R22 Surveillance Testing (71111.22)

a. Inspection Scope

The inspectors reviewed the UFSAR, procedure requirements, and technical

specifications to ensure that the surveillance activities listed below demonstrated that the

systems, structures, and/or components tested were capable of performing their

intended safety functions. The inspectors either witnessed or reviewed test data to

verify that the significant surveillance test attributes were adequate to address the

following:

  • Preconditioning

- 20 - Enclosure

  • Evaluation of testing impact on the plant
  • Acceptance criteria
  • Test equipment
  • Procedures
  • Test data
  • Testing frequency and method demonstrated technical specification operability
  • Test equipment removal
  • Restoration of plant systems
  • Updating of performance indicator data
  • Engineering evaluations, root causes, and bases for returning tested systems,

structures, and components not meeting the test acceptance criteria were correct

  • Reference setting data

The inspectors also verified that licensee personnel identified and implemented any

needed corrective actions associated with the surveillance testing.

  • On March 2, 2011, fuel handling area ventilation exhaust radiation monitor time

response test

  • On March 10, 2011, division 1 diesel generator monthly surveillance
  • On March 18, 2011, division 3 diesel generator monthly surveillance

valves at the remote shutdown panel

Specific documents reviewed during this inspection are listed in the attachment.

- 21 - Enclosure

These activities constitute completion of seven surveillance (one reactor coolant system

leakage detection, one inservice test, and five routine tests) testing inspection samples

as defined in Inspection Procedure 71111.22-05.

b. Findings

No findings were identified.

Cornerstone: Emergency Preparedness

1EP6 Drill Evaluation (71114.06)

.1 Emergency Preparedness Drill Observation

a. Inspection Scope

The inspectors evaluated the conduct of a routine licensee emergency drill on March 3,

2011, to identify any weaknesses and deficiencies in classification, notification, and

protective action recommendation development activities. The inspectors observed

emergency response operations in the simulator control room and emergency

operations facility to determine whether the event classification, notifications, and

protective action recommendations were performed in accordance with procedures. The

inspectors also attended the licensee drill critique to compare any inspector-observed

weakness with those identified by the licensee staff in order to evaluate the critique and

to verify whether the licensee staff was properly identifying weaknesses and entering

them into the corrective action program. As part of the inspection, the inspectors

reviewed the drill package and other documents listed in the attachment.

These activities constitute completion of one sample as defined in Inspection

Procedure 71114.06-05.

b. Findings

No findings were identified.

2. RADIATION SAFETY

Cornerstone: Occupational and Public Radiation Safety

2RS01 Radiological Hazard Assessment and Exposure Controls (71124.01)

a. Inspection Scope

This area was inspected to: (1) review and assess licensees performance in assessing

the radiological hazards in the workplace associated with licensed activities and the

implementation of appropriate radiation monitoring and exposure control measures for

both individual and collective exposures, (2) verify the licensee is properly identifying

and reporting Occupational Radiation Safety Cornerstone performance indicators, and

- 22 - Enclosure

(3) identify those performance deficiencies that were reportable as a performance

indicator and which may have represented a substantial potential for overexposure of

the worker.

The inspectors used the requirements in 10 CFR Part 20, the technical specifications,

and the licensees procedures required by technical specifications as criteria for

determining compliance. During the inspection, the inspectors interviewed the radiation

protection manager, radiation protection supervisors, and radiation workers. The

inspectors performed walkdowns of various portions of the plant, performed independent

radiation dose rate measurements and reviewed the following items:

  • Performance indicator events and associated documentation reported by the

licensee in the Occupational Radiation Safety Cornerstone

  • The hazard assessment program, including a review of the licenses evaluations

of changes in plant operations and radiological surveys to detect dose rates,

airborne radioactivity, and surface contamination levels

  • Instructions and notices to workers, including labeling or marking containers of

radioactive material, radiation work permits, actions for electronic dosimeter

alarms, and changes to radiological conditions

  • Programs and processes for control of sealed sources and release of potentially

contaminated material from the radiologically controlled area, including survey

performance, instrument sensitivity, release criteria, procedural guidance, and

sealed source accountability

  • Radiological hazards control and work coverage, including the adequacy of

surveys, radiation protection job coverage, and contamination controls; the use of

electronic dosimeters in high noise areas; dosimetry placement; airborne

radioactivity monitoring; controls for highly activated or contaminated materials

(non-fuel) stored within spent fuel and other storage pools; and posting and

physical controls for high radiation areas and very high radiation areas

  • Radiation worker and radiation protection technician performance with respect to

radiation protection work requirements

  • Audits, self-assessments, and corrective action documents related to radiological

hazard assessment and exposure controls since the last inspection

Specific documents reviewed during this inspection are listed in the attachment.

These activities constitute completion of the one required sample as defined in

Inspection Procedure 71124.01-05.

b. Findings

- 23 - Enclosure

Introduction. The inspectors identified a Green, noncited violation of Technical Specification 5.7.2, resulting from the licensees failure to use a qualified radiation

protection technician to provide direct continuous coverage of work in a locked high

radiation area.

Description. The inspectors reviewed Condition Report CR-GGN-2011-00655, which

documented the identification by Cooper Nuclear Station that a contractor seeking

employment as a radiation protection technician did not meet ANSI 18.1 requirements.

The finding, documented February 2, 2011, was discussed with Entergy sites during a

teleconference. Then, Grand Gulf Nuclear Station determined the individual had been

employed as a radiation protection technician at Grand Gulf Nuclear Station during

Refueling Outage 17, conducted in April and May 2010. In response, Grand Gulf

Nuclear Station reviewed the radiation surveys performed by the individual (from April 15

through May 13, 2010), concluded the surveys contained data comparable with that

documented in other surveys in the same areas under similar conditions, and closed the

condition report on February 8, 2011. The inspectors reviewed the radiation survey

records included in the condition report and noted something the licensee had not

addressed. On April 27, 2010, the individual had provided job coverage for work in a

locked high radiation area (an area with dose rates greater than 1000 mrem/hour).

Survey GG-1004-0660 identified the work area as the 128-foot auxiliary pipe chase,

above the reactor water cleanup pump rooms. Since the individual used by the licensee

to provide job coverage and surveillance in a locked high radiation area was not a

qualified radiation protection technician, the inspectors identified this as a performance

deficiency.

Analysis. The failure to use a qualified radiation protection technician to provide direct

continuous coverage of work in a locked high radiation area is a performance deficiency.

The finding was more than minor because it was associated with the Occupational

Radiation Safety Cornerstone attribute (exposure control) of program and process and

affected the cornerstone objective, in that, the failure to use qualified radiation protection

technicians to provide job coverage in a high radiation area with dose rates in excess of

1000 mrem/hr had the potential to increase personnel dose. Using the Occupational

Radiation Safety Significance Determination Process, the inspectors determined the

finding to have very low safety significance because: (1) it was not associated with

ALARA planning or work controls, (2) there was no overexposure, (3) there was no

substantial potential for an overexposure, and (4) the ability to assess dose was not

compromised. The inspectors identified no cross-cutting aspect associated with this

finding.

Enforcement. Technical Specification 5.7.2, controls for high radiation areas with dose

rates greater than 1000 mrem/hour, consists of all the controls for high radiation areas

(Technical Specification 5.7.1) plus it requires doors to the area remain locked except

during periods of access by personnel under an approved radiation work permit that

shall specify the dose rate levels in the immediate work areas and the maximum

allowable stay times for individuals in those areas. In lieu of the stay time specification

for the radiation work permit, direct or remote continuous surveillance may be made by

personnel qualified in radiation protection procedures to provide positive exposure

- 24 - Enclosure

control over the activities being performed within the area. Contrary to the above, during

work in an area with dose rates greater than 1000 mrem/hour on April 27, 2010, in lieu of

the stay time specification for the radiation work permit, direct or remote surveillance

was not made by personnel qualified in radiation protection procedures to provide

positive exposure control over the activities being performed within the area. Instead, an

unqualified person was assigned to provide surveillance of a locked high radiation on

April 27, 2010. The licensee initiated Condition Report CR-GGN-2011-01045 to

document the fact that it failed to identify this performance deficiency as part of the

review associated with the closure of Condition Report CR-GGN-2011-00655.

Because the violation was of very low safety significance and it was entered into the

licensees corrective action program, the violation is being treated as a noncited

violation, consistent with the enforcement policy. NCV 05000416/2011002-04, Failure

to Use a Qualified Radiation Protection Technician to Provide Direct Continuous

Coverage of Work in a Locked High Radiation Area.

2RS02 Occupational ALARA Planning and Controls (71124.02)

a. Inspection Scope

This area was inspected to assess performance with respect to maintaining occupational

individual and collective radiation exposures as low as is reasonably achievable

(ALARA). The inspectors used the requirements in 10 CFR Part 20, the technical

specifications, and the licensees procedures required by technical specifications as

criteria for determining compliance. During the inspection, the inspectors interviewed

licensee personnel and reviewed the following items:

  • Site-specific ALARA procedures and collective exposure history, including the

current 3-year rolling average, site-specific trends in collective exposures, and

source-term measurements

  • ALARA work activity evaluations/postjob reviews, exposure estimates, and

exposure mitigation requirements

  • The methodology for estimating work activity exposures, the intended dose

outcome, the accuracy of dose rate and man-hour estimates, and intended

versus actual work activity doses and the reasons for any inconsistencies

  • Records detailing the historical trends and current status of tracked plant source

terms and contingency plans for expected changes in the source term due to

changes in plant fuel performance issues or changes in plant primary chemistry

  • Radiation worker and radiation protection technician performance during work

activities in radiation areas, airborne radioactivity areas, or high radiation areas

  • Audits, self-assessments, and corrective action documents related to ALARA

planning and controls since the last inspection

- 25 - Enclosure

Specific documents reviewed during this inspection are listed in the attachment.

These activities constitute completion of the one required sample as defined in

Inspection Procedure 71124.02-05.

b. Findings

No findings were identified.

4. OTHER ACTIVITIES

4OA1 Performance Indicator Verification (71151)

.1 Data Submission Issue

a. Inspection Scope

The inspectors performed a review of the performance indicator data submitted by the

licensee for the fourth Quarter 2010 performance indicators for any obvious

inconsistencies prior to its public release in accordance with Inspection Manual

Chapter 0608, Performance Indicator Program.

This review was performed as part of the inspectors normal plant status activities and,

as such, did not constitute a separate inspection sample.

b. Findings

No findings were identified.

.2 Unplanned Scrams per 7000 Critical Hours (IE01)

a. Inspection Scope

The inspectors sampled licensee submittals for the unplanned scrams per 7000 critical

hours performance indicator for the period from the first quarter 2010 through the fourth

quarter 2010. To determine the accuracy of the performance indicator data reported

during those periods, the inspectors used definitions and guidance contained in NEI

Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 6.

The inspectors reviewed the licensees operator narrative logs, condition reports, event

reports, and NRC integrated inspection reports for the period of January 2010 through

December 2010 to validate the accuracy of the submittals. The inspectors also reviewed

the licensees condition report database to determine if any problems had been identified

with the performance indicator data collected or transmitted for this indicator and none

were identified. Specific documents reviewed are described in the attachment to this

report.

These activities constitute completion of one unplanned scrams per 7000 critical hours

sample as defined in Inspection Procedure 71151-05.

- 26 - Enclosure

b. Findings

No findings were identified.

.3 Unplanned Scrams with Complications (IE02)

a. Inspection Scope

The inspectors sampled licensee submittals for the unplanned scrams with

complications performance indicator for the period from first quarter 2010 through the

fourth quarter 2010. To determine the accuracy of the performance indicator data

reported during those periods, the inspectors used definitions and guidance contained in

NEI Document 99-02, Regulatory Assessment Performance Indicator Guideline,

Revision 6. The inspectors reviewed the licensees operator narrative logs, condition

reports, event reports, and NRC integrated inspection reports for the period of January

2010 through December 2010 to validate the accuracy of the submittals. The inspectors

also reviewed the licensees condition report database to determine if any problems had

been identified with the performance indicator data collected or transmitted for this

indicator and none were identified. Specific documents reviewed are described in the

attachment to this report.

These activities constitute completion of one unplanned scrams with complications

sample as defined in Inspection Procedure 71151-05.

b. Findings

No findings were identified.

.4 Unplanned Power Changes per 7000 Critical Hours (IE03)

a. Inspection Scope

The inspectors sampled licensee submittals for the unplanned power changes per 7000

critical hours performance indicator for the period from first quarter 2010 through the

fourth quarter 2010. To determine the accuracy of the performance indicator data

reported during those periods, the inspectors used definitions and guidance contained in

NEI Document 99-02, Regulatory Assessment Performance Indicator Guideline,

Revision 6. The inspectors reviewed the licensees operator narrative logs, condition

reports, event reports, and NRC integrated inspection reports for the period of January

2010 through December 2010 to validate the accuracy of the submittals. The inspectors

also reviewed the licensees condition report database to determine if any problems had

been identified with the performance indicator data collected or transmitted for this

indicator and none were identified. Specific documents reviewed are described in the

attachment to this report.

These activities constitute completion of one unplanned transients per 7000 critical

hours sample as defined in Inspection Procedure 71151-05.

- 27 - Enclosure

b. Findings

No findings were identified.

.5 Occupational Exposure Control Effectiveness (OR01)

a. Inspection Scope

The inspectors reviewed performance indicator data for the second quarter of 2010

through the fourth quarter of 2010. The objective of the inspection was to determine the

accuracy and completeness of the performance indicator data reported during these

periods. The inspectors used the definitions and clarifying notes contained in NEI

Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 6,

as criteria for determining whether the licensee was in compliance.

The inspectors reviewed corrective action program records associated with high

radiation area (greater than 1 rem/hr) and very high radiation area non-conformances.

The inspectors reviewed radiological, controlled area exit transactions greater than

100 mrem. The inspectors also conducted walkdowns of high radiation areas (greater

than 1 rem/hr) and very high radiation area entrances to determine the adequacy of the

controls of these areas.

These activities constitute completion of the occupational exposure control effectiveness

sample as defined in Inspection Procedure 71151-05.

b. Findings

No findings were identified.

.6 Radiological Effluent Technical Specifications/Offsite Dose Calculation Manual

Radiological Effluent Occurrences (PR01)

a. Inspection Scope

The inspectors reviewed performance indicator data for the second quarter of 2010

through the fourth quarter of 2010. The objective of the inspection was to determine the

accuracy and completeness of the performance indicator data reported during these

periods. The inspectors used the definitions and clarifying notes contained in NEI

Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 6,

as criteria for determining whether the licensee was in compliance.

The inspectors reviewed the licensees corrective action program records and selected

individual annual or special reports to identify potential occurrences such as

unmonitored, uncontrolled, or improperly calculated effluent releases that may have

impacted offsite dose.

- 28 - Enclosure

These activities constitute completion of the radiological effluent technical

specifications/offsite dose calculation manual radiological effluent occurrences sample

as defined in Inspection Procedure 71151-05.

b. Findings

No findings were identified.

4OA2 Identification and Resolution of Problems (71152)

Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity, Emergency

Preparedness, Public Radiation Safety, Occupational Radiation Safety, and

Physical Protection

.1 Routine Review of Identification and Resolution of Problems

a. Inspection Scope

As part of the various baseline inspection procedures discussed in previous sections of

this report, the inspectors routinely reviewed issues during baseline inspection activities

and plant status reviews to verify that they were being entered into the licensees

corrective action program at an appropriate threshold, that adequate attention was being

given to timely corrective actions, and that adverse trends were identified and

addressed. The inspectors reviewed attributes that included the complete and accurate

identification of the problem; the timely correction, commensurate with the safety

significance; the evaluation and disposition of performance issues, generic implications,

common causes, contributing factors, root causes, extent of condition reviews, and

previous occurrences reviews; and the classification, prioritization, focus, and timeliness

of corrective actions. Minor issues entered into the licensees corrective action program

because of the inspectors observations are included in the attached list of documents

reviewed.

These routine reviews for the identification and resolution of problems did not constitute

any additional inspection samples. Instead, by procedure, they were considered an

integral part of the inspections performed during the quarter and documented in

Section 1 of this report.

b. Findings

No findings were identified.

.2 Daily Corrective Action Program Reviews

a. Inspection Scope

In order to assist with the identification of repetitive equipment failures and specific

human performance issues for follow-up, the inspectors performed a daily screening of

- 29 - Enclosure

items entered into the licensees corrective action program. The inspectors

accomplished this through review of the stations daily corrective action documents.

The inspectors performed these daily reviews as part of their daily plant status

monitoring activities and, as such, did not constitute any separate inspection samples.

b. Findings

No findings were identified.

.3 Selected Issue Follow-up Inspection

a. Inspection Scope

During a review of items entered in the licensees corrective action program, the

inspectors recognized CR-GGN- 2009-05879 a corrective action item documenting

temperature switches for safety related ventilation system. The inspectors reviewed that

item as described in Inspection Procedure 71152.02 to verify, in part, licensee evaluation

and disposition of operability and reportability issues; consideration of extent of condition

and cause, generic implications, common cause, and previous occurrences;

classification and prioritization of the problems resolution commensurate with the safety

significance; and identification of corrective actions that were appropriately focused to

correct the problem.

These activities constitute completion of one in-depth problem identification and

resolution sample as defined in Inspection Procedure 71152-05.

b. Findings

No findings were identified.

4OA3 Event Follow-up (71153)

.1 (Closed) LER 05000416/2010-002-00, Control Room Air Conditioning Inoperability -

Loss of Both Trains

a. Inspection Scope

On October 14, 2010, while operating at approximately 100 percent power, the train B

control room air conditioner subsystem tripped on low oil pressure while the train A

control room air conditioner subsystem was out of service for maintenance. The control

room temperature increased and actions were taken to maintain control room

temperatures below the technical specification limit of 90 degrees Fahrenheit. The two

control room air conditioning subsystems were inoperable for 64 hours7.407407e-4 days <br />0.0178 hours <br />1.058201e-4 weeks <br />2.4352e-5 months <br /> and 24 minutes

until the train A control room air conditioner was declared operable.

The three possible failure mechanisms that the licensee identified in their root cause

evaluation were 1) the intermittent failure of the low oil differential pressure switch, 2) the

- 30 - Enclosure

intermittent failure of one or more loading/unloading mechanisms, and 3) one or more of

the temperature control valves were in an open condition or in a more than desired open

position. The licensee also identified a contributing cause of failure to exclude foreign

material during maintenance activities on the train B control room air conditioner.

Inspectors reviewed the circumstances surrounding the event, the licensees response

to the event, and the licensees corrective actions to preclude repetition. Documents

reviewed as part of this inspection are listed in the attachment. The enforcement

aspects of this finding are discussed in this section and in Section 1R12. This LER is

closed.

b. Findings

Introduction. The inspectors reviewed a self-revealing, Green noncited violation of 10

CFR Part 50, Appendix B, Criterion XVI, Corrective Action, after the licensee failed to

determine the cause and prevent recurrence of a significant condition adverse to quality

associated with the train B control room air conditioner compressor tripping due to low oil

pressure.

Description. On October 14, 2010, the train B control room air conditioner subsystem

tripped on low oil pressure while the train A control room air conditioner subsystem was

out of service for maintenance. The control room temperature increased, and actions

were taken to maintain control room temperatures below the technical specification limit

of 90 degrees Fahrenheit. The licensee determined that the event (i.e., one subsystem

inoperable and unavailable for maintenance while the other subsystem was inoperable

due to a trip) was reportable to the NRC. The two control room air conditioning

subsystems were inoperable for 64 hours7.407407e-4 days <br />0.0178 hours <br />1.058201e-4 weeks <br />2.4352e-5 months <br /> and 24 minutes until the train A control room

air conditioner was declared operable. This was a significant condition because it

rendered technical specification required equipment inoperable.

The licensees corrective actions to address the event involved performing a root cause

evaluation. The licensee concluded that the three possible failure mechanisms were 1)

an intermittent failure of low oil differential pressure switch, 2) an intermittent failure of

one or more loading/unloading mechanisms, and 3) failure of one or more thermal

expansion valves. The licensee also concluded that a contributing cause of the event

was the failure to exclude foreign material during maintenance activities of the system.

The licensee addressed each of the possible root causes, as well as the contributing

cause, since a single root cause could not be determined. The corrective action for the

three probable root causes included 1) ensuring that only original differential pressure

switches are used (or a suitable equivalent) for replacement; 2) revising planned

maintenance tasks to included instructions for the loader/unloader disassembly,

inspection and reassembly; 3) revising tasks for compressor A and B rebuilds; and 4)

revising compressor preventative maintenance tasks to record the degree of superheat

for each thermal expansion valve.

Despite the corrective actions implemented by the licensee, the train B control room air

conditioner compressor again tripped on December 13, 2010, due to low oil pressure.

After this trip and upon further evaluation, the licensee performed an additional

corrective action that installed an inline suction filter with smaller filtering diameter and

- 31 - Enclosure

larger surface area to remove foreign material from the system. The licensee also

modified the operator rounds to obtain daily readings of differential pressure across this

new filter and through calculation, determined a differential pressure necessary to

change the filter. The condition report that documented the December 13th event was

closed to the corrective actions associated with the October 14th compressor trip and the

new corrective action associated with the newly installed in line suction filter.

The licensee entered this event into their corrective actions program as condition report

CR-GGN-2010-07315. Since the use of the new inline suction filter, they have not had

any additional trips of the control room air conditioning B. The April 2011 inspection

showed that the filter had reduced foreign material on the compressor suction strainer by

40 percent from the March 2011 inspection. Also in May 2011, the licensee plans to

boroscope the evaporation section of the air conditioner to search for any other foreign

material.

Analysis. The inspectors determined that the failure to take corrective actions to prevent

recurrence of the train B control room air conditioner compressor tripping due to low oil

pressure was a performance deficiency. This finding was more than minor because it

was associated with the equipment performance attribute of the Mitigating Systems

Cornerstone and adversely affected the cornerstone objective to ensure the availability,

reliability, and capability of systems that respond to initiating events to prevent

undesirable consequences. Using Inspection Manual Chapter 0609, "Significance

Determination Process," Phase 1 worksheets, the inspectors determined that a Phase 2

estimate was required because the finding represented a loss of system safety function.

The plant-specific risk informed notebook does not include the evaluation of risk caused

by the loss of cooling to the main control room. Therefore, the senior reactor analyst

conducted a Phase 3 analysis.

The analyst noted that understanding the risk affect of control room chillers required a

review of the following items:

  • Loss of offsite power frequency (LOOP): Several alternative methods of cooling

control room equipment are available provided offsite power is available.

Therefore, the dominant risk impact of essential chillers is during a loss of offsite

power. The loss of offsite power frequency documented in the plant-specific

SPAR model is 3.59 x 10-2/year.

  • Loss of the opposite train probability (PCH-A): The performance deficiency only

affected Train B CRAC. Therefore, the Train A would still be available to cool the

main control room. The generic failure probability for a single train of safety-

related equipment is approximately 3 x 10-2/demand.

  • Exposure Period (EXP): Although the Train B CRAC system was placed in

service without correcting the failure mechanism on November 1, 2010, the

chiller continued to be utilized and run for much of the time until failure on

December 13, 2010. The analyst noted that the chiller ran from November 12

until it failed on December 13, 2010. Therefore, the time that the chiller was

actually unavailable to perform its 24-hour risk significant mission time was

- 32 - Enclosure

about 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> (the last 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of its run and the 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> it took to repair).

This gave an exposure time of 2 days.

  • Conditional Core Damage Probability (CCDP): In the worst case failure of

control room air conditioning would result in main control room abandonment.

The generic CCDP for shutting the reactor down from outside the main control

room is approximately 0.1.

The analyst determined that a bounding assessment of the change in core damage

frequency (CDF), can be calculated as follows:

CDF = LOOP * PCH-A * EXP * CCDP

= 3.59 x 10-2/year * 3 x 10-2/demand * 2 days/365 days/year * 0.1

= 5.9 x 10-7

Based on the above bounding analysis, the analyst determined that the change in core

damage frequency result was 5.9 x 10-7. This noncited violation was therefore

determined to be of very low safety significance (Green). This finding had a crosscutting

aspect in the area of problem identification and resolution associated with the corrective

action program component because licensee personnel failed to thoroughly evaluate the

multiple failures of the train B control room air conditioner compressor. P.1(c)

Enforcement. Title 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action,

states, in part, that in the case of a significant condition adverse to quality, measures

shall assure that the cause of the condition is determined and corrective action taken to

preclude repetition. Contrary to the above, plant personnel did not implement corrective

actions to preclude repetition of a significant condition adverse to quality associated with

the tripping of the train B control room air conditioning compressor due to low oil

pressure. Specifically, on December 13, 2010, the train B control room air conditioner

compressor tripped due to low oil pressure after the licensee had a performed a root

cause analysis to identify the cause and prevent recurrence of the compressor tripping

due to low oil pressure. Because the finding was of very low safety significance and has

been entered into the corrective action program as Condition Report CR-GGN-2010-

07315, this violation is being treated as a noncited violation, consistent with the NRC

Enforcement Policy. NCV 05000416/2011002-05, Failure to Prevent Recurrence of

Control Room Air Conditioner Compressor Tripping Due to Low Oil Pressure.

.2 Steam Leak in the Containment

a. Inspection Scope

On November 8, 2010, the inspectors responded to the control room to observe operator

response to a steam leak in containment. The newly installed mitigation monitoring

system positive displacement pump ejected the cylinder causing an approximate seven

gallons per minute reactor coolant leak. The inspectors observed operator actions,

control room briefs and overall plant response to the event. The inspectors also

- 33 - Enclosure

observed control room indications used to identify abnormal conditions in the

containment building. Documents reviewed for this inspection are listed in the

attachment.

b. Findings

Introduction. The inspectors reviewed a self-revealing, Green finding of EN-DC-115,

Engineering Change Process, involving the failure to maintain adequate design control

measures associated with the installation of the mitigation monitoring system.

Description. On November 8, 2010, at approximately 5:30 am, a reactor coolant

pressure boundary failure occurred at the skid mounted Online Noble Chemical -

Mitigation Monitoring System pump inside primary containment. The positive

displacement sample pump ejected the pump piston from the housing resulting in an

approximate 7 gpm leak of reactor coolant. The leak was not detected for approximately

4.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br />, resulting in the release of approximately 2,000 gallons of reactor coolant

which flashed directly to steam. The steam leak resulted in a reactor recirculation system

flow control valve lockup (due to HPU motor failure) and approximately 15,000 square

feet of contaminated area in the primary containment structure.

The inspectors reviewed the mitigation monitoring system modification documentation

and found that the design documentation did not appropriately address the design

requirements for the installation of the mitigation monitoring system pump. The licensee

failed to ensure proper validation testing for the pump prior to installation in the plant.

Specifically, they did not ensure that the pump would be able to withstand the system

operating pressures and temperatures in which it was installed. They failed to validate

the design, which had a single point vulnerability, that resulted in the piston injecting

from the pump and caused the leakage and contamination of the containment. In

addition, the inspectors reviewed the root cause analysis of the event and found that the

licensee failed to apply the appropriate oversight of the engineering vendor due to

weaknesses in the procedure EN-DC-114, "Vendor Quality Management/Oversight."

The licensee entered this event into their corrective actions program as condition report

CR-GGN-2010-07852. The licensee has currently removed the mitigation monitoring

system pump from the plant, and isolated the mitigation monitoring system skid from the

reactor water cleanup system. They are evaluating the design to make appropriate

changes to ensure a repeat of this event will not occur.

Analysis. The failure to implement adequate design control measures for modifications

to the plant, which impacted the reactor coolant pressure boundary, is a performance

deficiency. Specifically procedure EN-DC-115, Engineering Change Process, step

5.1[1], requires during the engineering change development a choice of new technology

or application is an error precursor which will need to have defensive functions built into

the design, testing and maintenance, including developing in-house expertise. Contrary

to this, the engineering change package that implemented this design change failed to

ensure proper validation testing was performed prior to installation in the plant. The

finding is more than minor because it affects the design control attribute of the Barrier

Integrity Cornerstone to provide reasonable assurance that physical design barriers

- 34 - Enclosure

protect the public from radionuclide releases caused by accidents or events. Therefore,

using inspection Manual Chapter 0609, "Significance Determination Process," Phase 1

Worksheet for LOCA initiators, the inspectors concluded that the finding was of very low

safety significance (Green) because the failure of the mitigation monitoring system would

not have exceeded technical specifications limits for identified leakage in the reactor

coolant system. This finding has a crosscutting aspect in the area of human

performance associated with the work practices component because the licensee failed

to adequately oversee the design of the mitigation monitor system such that nuclear

safety is supported. H.4(c)

Enforcement. No violation of regulatory requirements occurred. This finding was

entered into the licensees corrective action program as CR-GGN-2010-07852, and is

identified as: FIN 05000416/2011002-06, Inadequate Design Control for the Mitigation

Monitoring System Modification.

4OA5 Other Activities

1. (Closed) Temporary Instruction (TI) 2515/179, Verification of Licensee Responses to

NRC Requirement for Inventories of Materials Tracked in the National Source Tracking

System Pursuant to Title 10, Code of Federal Regulations, Part 20.2207 (10 CFR

20.2207)

a. Inspection Scope

An NRC inspection was performed to confirm that the licensee has reported their initial

inventories of sealed sources pursuant to 10 CFR 20.2207 and to verify that the National

Source Tracking System database correctly reflects the Category 1 and 2 sealed

sources in custody of the licensee. Inspectors interviewed personnel and performed the

following:

  • Reviewed the licensees source inventory
  • Verified the presence of any Category 1 or 2 sources
  • Reviewed procedures for and evaluated the effectiveness of storage and handling

of sources

  • Reviewed documents involving transactions of sources
  • Reviewed adequacy of licensee maintenance, posting, and labeling of nationally

tracked sources

b. Findings

While comparing the National Source Tracking System database information, the

Licensees information submittal, and original source certificates, the inspector noted

that the licensee erroneously reported information for one of the four sources meeting

the reporting criteria. The licensee used original leak test data and submitted the wrong

- 35 - Enclosure

serial number and activity date for the source. The licensee reviewed all relevant data

and submitted corrected documents within the five business days allowed by

10 CFR 20.2207(g). This finding was considered as an administrative error and of minor

safety significance.

4OA6 Meetings

Exit Meeting Summary

On February 18, 2011, the inspectors presented the results of the radiation safety inspections to

Mr. J. Browning, General Plant Manager, and other members of the licensee staff. The licensee

acknowledged the issues presented. The inspectors asked the licensee whether any materials

examined during the inspection should be considered proprietary. No proprietary information

was identified.

On April 14, 2011, the inspectors presented the inspection results to M. Perito, Site Vice-

President Operations and other members of the licensee staff. The licensee acknowledged the

issues presented. The inspector asked the licensee whether any materials examined during the

inspection should be considered proprietary. No proprietary information was identified.

4OA7 Licensee-Identified Violations

The following violations of very low safety significance (Green) were identified by the licensee

and are violations of NRC requirements which meet the criteria of Section 2.3.2 of the NRC

Enforcement Policy for being dispositioned as noncited violations.

.1 Technical Requirements Manual (TRM) section 6.2.1 requires that fire detection

instrumentation for each fire detection zone shall be operable and if the required

detection system is inoperable an hourly fire watch must be established. Contrary to

this, on February 9, 2011 the licensee identified that fire detection instrumentation for fire

zone 2-12 had been left in the non-audible alarm for the main control room on the fire

computer when the limiting condition for operations was cleared on December 8, 2010

when zone was returned to operable status. The control room supervisor on February 9,

2011, discovered this condition when entering a fire-limiting condition for operation for

the division 1 diesel generator room to allow welding. The licensee determined that it

had been in non-audible status from December 8, 2010, through February 9, 2011. This

issue was documented in the licensees corrective action program in condition report

CR-GGN-2011-00851. The senior reactor analyst from region IV performed a bounding

evaluation of the change in risk caused by this condition. According to the Grand Gulf

Updated Final Safety Analysis Report, Fire Zone 2-12 only contains Division I

equipment. A fire that consumed the equipment in the area could not result in a loss of

offsite power or other unplanned transient. Given the ignition frequency of the area, the

60-day exposure period, and the conditional core damage probability with the loss of the

Division I emergency diesel generator, the analyst calculated that the change in risk was

significantly less than 1E-6. Therefore, this finding was of very low safety significance

(Green).

- 36 - Enclosure

- 37 - Enclosure

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee Personnel

R. Benson, Manager (Acting), Radiation Protection

J. Browning, General Plant Manager

D. Coulter, Senior Licensing Specialist

H Farris, Assistant Operation Manager

K. Higgenbotham, Planning and Scheduling Manager

J. Houston, Maintenance Manager

R. Jackson, Licensing

C. Lewis, Manager, Emergency Preparedness

C. Perino, Licensing Manager

M. Perito, Site Vice President of Operations

M. Richey, Director, Nuclear Safety Assurance

F. Rosser, Supervisor, Dosimetry

R. Sumrall, Superintendant, Operations Training

R. Sylvan, Supervisor, Radiation Protection

T. Trichell, Radiation Protection Manager

D. Wiles, Engineering Director

R. Wilson, Manager, Quality Assurance

E. Wright, Supervisor, Radiation Protection

NRC Personnel

R. Smith, Senior Resident Inspector

A-1 Attachment

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened and Closed

Transient Combustible Stored in the Fire Exclusion Zone Near the

05000416/2011002-01 NCV

Independent Spent Fuel Storage Installation (Section 1R05)

Failure to Update Available Low Pressure Coolant Injection Loops05000416/2011002-02 NCV

in the Updated Final Safety Analysis Report (Section 1R12)

Failure to Demonstrate Maintenance Effectiveness of Train B

05000416/2011002-03 NCV

Control Room Air Conditioner(Section 1R12)

Failure to Use a Qualified Radiation Protection Technician to

05000416/2011002-04 NCV Provide Direct Continuous Coverage of Work in a Locked High

Radiation Area (Section 2RS01)

Failure to Prevent Recurrence of Control Room Air Conditioner

05000416/2011002-05 NCV

Compressor Tripping Due to Low Oil Pressure (Section 4OA3)

Inadequate Design Control for the Mitigation Monitoring System

05000416/2011002-06 FIN

Modification (Section 4OA3)

Closed

Verification of Licensee Responses to NRC Requirement for

Inventories of Materials Tracked in the National Source Tracking

TI 2515/179 TI

System Pursuant to Title 10, Code of Federal Regulations,

Part 20.2207 (10 CFR 20.2207) (Section 4OA5)

05000416/2010-002-00 LER Control Room Air Conditioning Inoperability - Loss of Both Trains

(Section 4OA3)

A-2 Attachment

LIST OF DOCUMENTS REVIEWED

Section 1RO1: Adverse Weather Protection

PROCEDURE

NUMBER TITLE REVISION

ENS-EP-302 Severe Weather Response 11

05-1-02-VI-2 Hurricanes, Tornados, and Severe Weather 113

04-1-01-P41-1 Standby Service Water System 133

04-1-01-N71-1 Circulating Water System 72

04-1-03-A30-1 Cold Weather Protection 20

OTHER

NUMBER TITLE DATE

SSW Pump Discharge Temperatures January 6-10,

2011

WORK ORDER

WO 52233022

Section 1RO4: Equipment Alignment

PROCEDURE

NUMBER TITLE REVISION

9.3-17 - 9.3-25 GG UFSAR 3

07-1-34-C41- Standby Liquid Control Pump 10

C001-1

04-1-01-C41-1 Standby Liquid Control System 119

04-1-01-P75-1 Standby Diesel Generator System 88

04-1-01-P41-1 Standby Service Water System 133

04-1-01-E12-1 System Operating Instructions Residual Heat Removal 137

System

04-1-01-E12-1 Residual Heat Removal B 137

04-1-01-E12-1 Residual Heat Removal C 137

A-3 Attachment

PROCEDURE

NUMBER TITLE REVISION

04-1-01-E12-1 Residual Heat Removal B Attachment IB 137

04-1-01-E12-1 Residual Heat Removal B Attachment IIIB 137

04-1-01-E12-1 Residual Heat Removal C Attachment IC 137

04-1-01-E12-1 Residual Heat Removal B Attachment VB 137

04-1-01-E12-1 Residual Heat Removal (Interface Valves) Attachment IIE 137

04-1-01-P41-1 Standby Service Water System Attachment IIB 133

04-1-01-P41-1 Standby Service Water System Attachment IIIB 113

OTHER

NUMBER TITLE DATE

11-4568 Scaffolding Evaluation Request February 15,

2001

CALCULATION

NUMBER TITLE DATE

9645 Diesel Generator Building Walls August 2,

1976

C-C400 SSW CT and Basin (Pump-House) Tornado and No May 28, 1976

Earthquake

C-0-100 Diesel Generator Bldg. Walls Tornado Wind Load W August 2,

1976

WORK ORDER

WO 52256371 WO 00260559 WO 00259801

Section 1RO5: Fire Protection

PROCEDURE

NUMBER TITLE REVISION

Fire Pre-Plan DG-03 Division II Diesel Generator Room 3

9A-343 - 9A347 GG UFSAR

Fire Pre-Plan A-02 RHR A Pump Room 1A103 1

A-4 Attachment

PROCEDURE

NUMBER TITLE REVISION

Fire Pre-Plan A-03 RCIC Pump Room 1A104 1

Fire Pre-Plan A-04 RHR B Pump Room 1A105 1

9A.5.2.2 Safe Shutdown Equipment

Appendix 9B Fire Protection Program

CONDITION REPORT

CR-GGN-2011-00862 CR-GGN-2011-01939 CR-GGN-2011-00851

CR-GGN-2011-00455

Section 1RO6: Flood Protection Measures

PROCEDURE

NUMBER TITLE REVISION /

DATE

9A-336 - 9A338 GG UFSAR

9A.5.59 GG UFSAR FIRE AREA 59

EN-OP-104 Operability Determination Process Immediate Determination 4

For Degraded of Nonconforming Conditions

OTHER

NUMBER TITLE DATE

Russell Daniel Oil Co. Inc. Delivery Date Schedule February 10,

2011

CONDITION REPORT

CR-GGN-2011-00198 CR-GGN-2011-00562 CR-GGN-2011-00654

WORK ORDER

WO 52281566 WO 52210679 03 WO 52210679 02

WO 52210679 01 WO 00041743 WO 52210679

A-5 Attachment

ENGINEERING CHANGE

EC No. 24971 EC No. 24904 EC No. 24972

Section 1R07:

PROCEDURE

NUMBER TITLE REVISION

08-S-03-10 Chemistry Procedure-Closed Loops 48

OTHER

NUMBER TITLE DATE

CCE 2006-0002 Commitment Change Evaluation Form

Letter Response to Generic Letter 89-13; Service Water System January 29,

Problems Affecting Safety-Related Equipment 1990

WORK ORDER

WO 00178965 01 WO 00178965 02 WO 00178965 03

Section 1R11: Licensed Operator Requalification Program

OTHER

NUMBER TITLE REVISION /

DATE

GSMS-LOR- LOR Training-Double Recirculation Pump Trip/ATWS January 18,

WEX03 2011

Rev 17

Turnover and Simulator Differences 2011 Cycle 1 Simulator 1

Training

Per Control Room Walkdown, Modifications to TREX Load January 7,

2011

Letter Emergency Preparedness January 31, 2011 Simulator Drill February 1,

Performance Indicators 2011

A-6 Attachment

Section 1R12: Maintenance Effectiveness

PROCEDURE

NUMBER TITLE REVISION /

DATE

EN-FP-S-001- Engineering Standard-Appendix R Emergency Lighting Units January 10,

Multi 2011

07-S-12-143 Big Beam Emergency Light Inspection, Battery Capacity 2

Verification, and Functional Test

EN-DC-203 Maintenance Rule Program 1

EN-DC-206 Maintenance Rule (a)(1) Process 1

EN-DC-207 Maintenance Rule Periodic Assessment 1

NMM EN-LI-118 Root Cause Evaluation Report Attachment IV (54 of 54) 12

EN-DC-205 Maintenance Rule Monitoring 2

GG UFSAR Table 7.5-1 Safety-Related Display

Instrumentation

GG UFSAR Table 7.5-2 Post-Accident Monitoring

Instrumentation

GG UFSAR 6.3 Emergency Core Cooling Systems 0

03-1-01-3 Integrated Operating Instructions Plant Shutdown 118

OTHER

NUMBER TITLE REVISION /

DATE

Emergency Lighting - GGNS Discussion of Recent Activities

Maintenance Rule Expert Panel June 22, 2010 Meeting

Minutes

Maintenance Rule Expert Panel August 10, 2010 Meeting

Minutes

Entergy Nuclear-GGNS Maintenance Rule Program Basis 0

Document, Control Room and Emergency Lighting (Z92)

System

Z92 Maintenance Rule Database Control Room and Emergency

Lighting

TM M348X.8001 Midtron 3200 Battery Conductance Tester

A-7 Attachment

OTHER

NUMBER TITLE REVISION /

DATE

VMA97/0181 Emergency Lights

Maintenance Rule Database Information - Main Control March 21,

Room Air Conditioning (Z51) System 2009 to

December

23, 2010

Maintenance Rule Database Z51 Control Room HVAC

System

EC No.: 27856 Engineering Evaluation 0

Maintenance Rule Program (a)(1) Evaluation and Action Plan

Main Control Room Air Conditioning (Z51) System

Agenda for Maintenance Rule Expert Panel Meeting February 4,

2010

RHR Heat Exchanger SSW Flow Indication (a)(1) Status

Maintenance Rule Database E12 RHR System

Maintenance Rule Program (a)(1) Evaluation for the Residual

Heat Removal (E12/RHR) System CR-GGN-2009-0754 CA

No. 002

Maintenance Rule (a)(1) Evaluation Standby Service Water

(P41) System (GR-GGN-2010-00305)

Agenda Items from Maintenance Rule Expert Panel Meeting June 24,

2010

Agenda Items from Maintenance Rule Expert Panel Meeting June 22,

2010

CONDITION REPORT

CR-GGN -2009-05330 CR-GGN -2010-00381 CR-GGN -2010-04575

CR-GGN -2010-04585 CR-GGN -2010-06346 CR-GGN -2011-00481

CR-GGN -2011-00521 CR-GGN -2011-01212 CR-GGN-2011-01650

CR-GGN-2010-01984 CR-GGN-2011-11505 CR-GGN-2011-01308

CR-GGN-2010-07315 CR-GGN-2009-00842 CR-GGN-2009-00754

GR-GGN-2009-01729 CR-GGN-2009-02477 CR-GGN-2009-03394

CR-GGN-2009-02947 CR-GGN-2009-02848 CR-GGN-2009-03292

CR-GGN-2009-03574 CR-GGN-2009-03592 CR-GGN-2009-04219

A-8 Attachment

CR-GGN-2010-01031 CR-GGN-2009-04048 CR-GGN-2009-05930

CR-GGN-2009-05215 CR-GGN-2009-05932 CR-GGN-2009-05472

CR-GGN-2009-06066 CR-GGN-2009-04733 CR-GGN-2010-00036

CR-GGN-2010-01329 CR-GGN-2011-00789 CR-GGN-2010-07351

CR-GGN-2010-04009 CR-GGN-2010-05892 CR-GGN-2011-00791

CR-GGN-2011-00820 CR-GGN-2011-00985 CR-GGN-2009-01204

CR-GGN-2010-00684 CR-GGN-2010-05290 CR-GGN-2010-01585

CR-GGN-2010-00800 CR-GGN-2010-01474 CR-GGN-2010-01337

CR-GGN-2009-05508 CR-GGN-2010-01320 CR-GGN-2010-01345

CR-GGN-2009-05731 CR-GGN-2009-06174 CR-GGN-2010-02797

CR-GGN-2010-02200 CR-GGN-2010-03655 CR-GGN-2010-04629

CR-GGN-2010-02990 CR-GGN-2010-03241 CR-GGN-2009-00350

CR-GGN-2009-00426 CR-GGN-2009-00846 CR-GGN-2009-01518

CR-GGN-2010-02805 CR-GGN-2010-04015 CR-GGN-2010-03333

CR-GGN-2010-04625 CR-GGN-2010-04255 CR-GGN-2009-05527

CR-GGN-2010-02974 CR-GGN-2010-06137 CR-GGN-2010-05208

CR-GGN-2010-05330 CR-GGN-2010-04686 CR-GGN-2010-04963

CR-GGN-2010-05572 CR-GGN-2010-03650 CR-GGN-2010-06978

CR-GGN-2010-06148 CR-GGN-2010-06150 CR-GGN-2010-05328

CR-GGN-2010-06142 CR-GGN-2011-00403 CR-GGN-2011-00749

CR-GGN-2011-00819 CR-GGN-2011-00850 CR-GGN-2010-06895

CR-GGN-2010-06918 CR-GGN-2011-01212 CR-GGN-2010-05147

WORK ORDER

WO 52255810 WO 52223396 WO 52271013 01

WO 52196016 WO 52220690

Section 1R13: Maintenance Risk Assessment and Emergent Work Controls

PROCEDURE

NUMBER TITLE REVISION

EN-WM-101 On-line Work Management Process 7

EN-WM-100 Work Request Generation, Screening and Classification 5

EN-WM-101 On-line Work Management Process 8

EN-WM-101 On Line Emergent Work Addition/Deletion Approval Form for 7

the Week of March 7, 2011

A-9 Attachment

PROCEDURE

NUMBER TITLE REVISION

EN-WM-101 On Line Emergent Work Addition/Deletion Approval Form for 7

the Week of February 28, 2011

WORK ORDER

WO250074 WO247598 WO52290243

WO52290462 WO52290463 WO52290464

WO70346 WO52291451 WO52291458

WO52291454 WO52291456 WO52291689

WO52291690 WO261213 WO52284287

WO52269835 WO52290236 WO52290463

WO52290464 WO52291844 WO52291454

WO52291456 WO261601 WO250966-02

WO237429 WO256910-01 WO52290639

WO52287735 WO52290638 WO52287736

WO52276935 WO260417 WO260212-02

WO260212-01 WO00219198 WO260529-07

WO52204865 WO260503 WO52243284

WO260529-07 WO52204865 WO52199495

WO255787-01,02,03,04 WO52249417 WO52271012

WO261175 WO259639 WO257881

WO200935-02 WO00257063 WO224859

WO261706 WO255360-08 WO263130

WO261181-01 and 02 WO262143 WO234988-04

WO234992-04 WO52250110-03 WO234985-04

WO259003-05 WO259005-05 WO259007-05

WO112951-08 WO52270042 WO52259286

WO52275616 WO52288663 WO52290468

WO52270252 WO52291424 WO52270250

WO52291423 WO235034 WO52288844

WO51563342 WO160041 WO52290473

WO52281103

A-10 Attachment

Section 1R15: Operability Evaluations

PROCEDURE

NUMBER TITLE REVISION

EN-OP-104 Operability Determination Process 4

EN-DC-115 EC No. 20228 0

CALCULATION

NUMBER TITLE REVISION

PDS0170B SSW Basin A Relief Valve 2

DRAWING

NUMBER TITLE REVISION

FSK-M-KC187- Design Change Drawing SSW Basin A and B 8

01C1-Y

Design Change Drawing Reinforced Concrete Distribution 8

Support System Tower Elevation 157-8

OTHER

NUMBER TITLE REVISION /

DATE

2007-029 LBDCR Initiation

Grand Gulf Nuclear Station, Unity 1 - Conforming License July 18, 2007

Amendment to Incorporate the Mitigation Strategies Required

by Section B.5.b of the Commission Order EA - 02 - 026

GNRO- Supplementary Response Regarding Implementation Details June 7, 2007

2007/00037 for the Phase 2 and 3 Mitigation Strategies Grand Gulf

Nuclear Station

NEI 06-12 B.5.b Phase 2 & 3 Submittal Guideline Rev 2

December

2006

7-15 GG FSAR Rev 59

9.5-3 GG UFSAR

Attachment 9.2 Immediate Determination for Degraded of Nonconforming

Conditions CR-GGN-2011-01512

A-11 Attachment

OTHER

NUMBER TITLE REVISION /

DATE

Attachment 9.5 Operability Evaluation CR-GGN-2011-00155

NUS Switch Status

CONDITION REPORT

CR-GGN-2011-01173 CR-GGN-2011-00765 CR-GGN-2011-00155

CR-GGN-2011-00766 CR-GGN-2011-00799 CR-GGN-2011-01512

CR-GGN-2009-06838 CR-GGN-2011-01349 CR-GGN-2011-04701

CR-GGN-2011-00369 CR-GGN-2011-00643 CR-GGN-2011-00647

CR-GGN-2011-00665 CR-GGN-2011-00666 CR-GGN-2011-00667

CR-GGN-2011-00668 CR-GGN-2011-00669 CR-GGN-2011-00670

CR-GGN-2011-00671

Section 1R18: Plant Modifications

PROCEDURE

NUMBER TITLE REVISION

EN-DC-136 Temporary Modifications 5

EN-LI-102 Corrective Action Process 16

DRAWING

NUMBER TITLE REVISION

E-1187-007 E31 Leak Detection System RWCU Flow Circuit Computer 7

Input

E1165014 Schematic Design Rod Control and Information System Rod 13

Position Information and SCRAM Time Test

E1173028 Schematic Design Reactor Protection System Testability 6

M1051A Main and Reheat System 33

OTHER

NUMBER TITLE

06-OP-1000-D-0001 Log Data

A-12 Attachment

OTHER

NUMBER TITLE

CR-GGN-2009- CR Periodic Review (initial at 6 months/follow by annual)

02198 CA 26 and/or Long Tem CA Classification Form

CONDITION REPORT

CR-GGN-2009-02198 CR-GGN-2010-04451 CR-GGN-2011-01231

WORK ORDER

WO00238932 WO00238928 WO00193921

WO00193920 WO002239736-01 WO002239736-02

WO002239736-03

ENGINEERING CHANGE

EC22768 EC22625 EC22635

Section 1R19: Postmaintenance Testing

PROCEDURE

NUMBER TITLE REVISION /

DATE

06-OP-1E12-Q- LPCI/RHR Subsystem A MOV Functional Test 112

0005

06-OP-1E12-Q- LPCI/RHR Subsystem A Quarterly Functional Test 121

0023

06-0P-1E12- LPCI/RHR System B MOV Functional Test 111

0006

06-OP-1P41-Q- Standby Service Water Loop A Valve AND Pump Operability 119

0004 Test

04-1-03-P75-1 Div 1 Diesel Generator Unexcited Run 7

06-OP-1P75-M- Data Sheet III Standby Diesel Generator 11 Functional Test February 12,

001 2011

07-S-12-40 General Cleaning and Inspection of Rotating Electrical 2

Equipment

07-S-12-146 General Maintenance Instruction Motor Off Line Diagnostic 1

A-13 Attachment

PROCEDURE

NUMBER TITLE REVISION /

DATE

Data Acquisition

07-S-12-55 Insulation Resistance Testing 10

06-IC-1E22-Q- HPCS System Flow Rate - Low (Bypass) Functional Test 104

0004

OTHER

NUMBER TITLE DATE

RPS Motor GEN B - MCE Stator February 2,

2011

HPCS Min Flow Valve Position March 18,

2011

DRAWING

NUMBER TITLE DATE

BRKR No. 52- IC71SOOIOB

142229

BRKR No. 52- IC7IS003B (Local C71-S003B)

142229

BRKR No. 52- IC7IS003D (Local C71-S003D)

142229

Timeline for Events leading to NRC Notification Call on March 18,

HPCS 2011

CONDITION REPORT

CR-GGN-2011-00945

WORK ORDER

WO52311451 WO52311569 WO52285575

WO00251847 WO52224645 WO52223715

WO00262318 WO00259110-01 WO00259110-03

WO00237650-01 WO00237650-04 WO00237650-05

WO00237650-06 WO52304041 WO00270205-01

A-14 Attachment

WO00270205-02

Section 1R22: Surveillance Testing

PROCEDURE

NUMBER TITLE REVISION

06-CH-1B21-O- Reactor Coolant Routine Chemistry-Sample February 23, 106

0002 2011

06-CH-1B21-O- Reactor Coolant Routine Chemistry-Sample February 18, 106

0002 2011

06-CH-1B21-O- Plant Operations Manual-Reactor Coolant Routine Chemistry 106

0002

06-CH-1B21-W- Reactor Coolant Dose Equivalent Iodine 104

0008

06-OP-1C61-R- Functional Checks with E51 Valves 109

0002

06-OP-1P75-M- Standby Diesel Generator Functional Test 132

0001

06-IC-1D17-R- Fuel Handling Area Ventilation Exhaust High High Radiation 102

0010 Electronics Time Response Test

04-1-01-P81-1 High Pressure Core Spray Diesel Generator 67

06-OP-1P81-M- HPCS Diesel Generator 13 Functional Test 123

0002

EN-OP-109 Conduct of Operations 2

OTHER

NUMBER TITLE DATE

Drywell Unidentified Leakage Rate vs. A Recirc Seal Delta June 2010-

T January 2011

CONDITION REPORT

CR-GGN-2011-01932 CR-GGN-2011-01868

WORK ORDER

WO52271012 WO52289870 WO52288401

WO52261837 WO52307262 WO00270146-01

A-15 Attachment

Section 1EP6: Drill Evaluation

OTHER

NUMBER TITLE DATE

Emergency Facility Log March 3, 2011

Repair and Corrective Action Table March 3, 2011

Emergency Notification Form 1-7 for EP Drill March 3, 2011

GGNS 2011 1st Quarter ERO Training Drill

CONDITION REPORT

CR-GGN-2011-01481 CR-GGN-2011-01486 CR-GGN-2011-01495

CR-GGN-2011-01499 CR-GGN-2011-01510 CR-GGN-2011-01519

CR-GGN-2011-01520 CR-GGN-2011-01522

Section 2RS01: Radiological Hazard Assessment and Exposure Controls

PROCEDURES

NUMBER TITLE REVISION

EN-RP-100 Radiation Worker Expectations 6

EN-RP-101 Access Control for Radiologically Controlled Areas 5

EN-RP-102 Radiological Control 2

EN-RP-106 Radiological Survey Documentation 2

01-S-08-1 Administration of the GGNS Radiation Protection Program 105

01-S-08-6 Radioactive Source Control 113

08-S-02-50 Radiological Surveys and Surveillances 116

AUDITS, SELF-ASSESSMENTS, AND SURVEILLANCES

NUMBER TITLE DATE

LO-GLO-2010-93 Pre-NRC Rad Hazard Assessment and Exposure December 16, 2010

Controls Assessment

CONDITION REPORTS

CR-GGN-2011-00183 CR-GGN-2011-00551 CR-GGN-2011-00655 CR-GGN-2011-00926

CR-GGN-2011-00740

A-16 Attachment

RADIOLOGICAL SURVEY

NUMBER TITLE DATE

GG-1102-0146 Routine Daily Surveys February 15, 2011

GG-1012-0083 208 CTMT Entire Elevation December 7, 2010

GG-1102-0152 208 CTMT Entire Elevation February 15, 2011

GG-1012-0118 119 AB RHR A Room December 9, 2010

GG-1012-0086 119 AB RHR A Room February 7, 2011

GG-1011-0254 119 AB RHR B Room November 30, 2010

GG-1101-0156 119 AB RHR B Room January 16, 2011

GG-1011-0064 93 Aux RHR C & ADHR Hx Rooms November 6, 2010

GG-1102-0044 93 Aux RHR C & ADHR Hx Rooms February 3, 2011

GG-1011-0018 119 Aux Piping Penetration & Valve Room November 2, 2010

GG-1102-0041 119 Aux Piping Penetration & Valve Room February 3, 2011

GG-1011-0063 93 Aux HPCS Pump Room November 6, 2010

GG-1102-0042 93 Aux HPCS Pump Room February 3, 2011

RADIATION WORK PERMITS

NUMBER TITLE

20101005 Tours and Inspections into all areas

20111054 Locked High Radiation Area Entries for Plant/System Investigations, Valve

Manipulations, Tagouts, and Misc. Activities

20111058 Maintenance in HRA /HCA & Above

Section 2RS02: Occupational ALARA Planning and Controls

PROCEDURES

NUMBER TITLE REVISION

EN-RP-105 Radiological Work Permits 9

EN-RP-110 ALARA Program 7

AUDITS, SELF-ASSESSMENTS, AND SURVEILLANCES

NUMBER TITLE DATE

LO # LO-GLO- Pre-NRC Inspection for ALARA Planning and Controls- November 9, 2010

2010-00094 Assessment

CONDITION REPORTS

A-17 Attachment

CR-GGN-2011-00425 CR-GGN-2011-00425 CR-GGN-2010-06335

RADIATION WORK PERMIT PACKAGES

NUMBER TITLE

2010-1402 Refuel Floor High Water Activities

2010-1403 Reactor Disassemble/Reassemble

2010-1508 Under Vessel Activities

2010-1530 B Recirc Pump Replacement

2010-1534 B21F011B Stem Replacement

Section 4OA1: Performance Indicator Verification

PROCEDURE

NUMBER TITLE REVISION

st

EN-LI-114 1 Quarter 2010 Unplanned Scrams per 7,000 Critical 4

Hours

EN-LI-114 2nd Quarter 2010 Unplanned Scrams per 7,000 Critical 4

Hours

EN-LI-114 3rd Quarter 2010 Unplanned Scrams per 7,000 Critical 4

Hours

EN-LI-114 4th Quarter 2010 Unplanned Scrams per 7,000 Critical 4

Hours

EN-LI-114 1st Quarter 2010 Unplanned Scrams with Complications 4

EN-LI-114 2nd Quarter 2010 Unplanned Scrams with Complications 4

EN-LI-114 3rd Quarter 2010 Unplanned Scrams with Complications 4

EN-LI-114 4th Quarter 2010 Unplanned Scrams with Complications 4

EN-LI-114 1st Quarter 2010 Unplanned Power Changes per 7,000 4

Critical Hours

EN-LI-114 2nd Quarter 2010 Unplanned Power Changes per 7,000 4

Critical Hours

EN-LI-114 3rd Quarter 2010 Unplanned Power Changes per 7,000 4

Critical Hours

EN-LI-114 4th Quarter 2010 Unplanned Power Changes per 7,000 4

Critical Hours

A-18 Attachment

OTHER

NUMBER TITLE

January 2010 Core Thermal Power

February 2010 Core Thermal Power

March 2010 Core Thermal Power

April 2010 Core Thermal Power

May 2010 Core Thermal Power

June 2010 Core Thermal Power

July 2010 Core Thermal Power

August 2010 Core Thermal Power

September 2010 Core Thermal Power

October 2010 Core Thermal Power

November 2010 Core Thermal Power

December 2010 Core Thermal Power

Section 4OA2: Identification and Resolution of Problems

OTHER

NUMBER TITLE DATE

GGNS Position on Riley Temperature Switch Replacement

Maintenance Rule Program Functional Failures-Riley

Temperature Switches

NUS Switch Status February 2,

2011

Riley History Discussion by Lee Eaton

Riley History Presentation to 2009 PInR

CONDITION REPORT

CR-GGN-2009-05879

A-19 Attachment

Section 4OA3: Event Follow-Up

PROCEDURE

NUMBER TITLE REVISION

EN-DC-167 Classification of Structures, Systems, and Components 3

EN-HU-103 Human Performance Error Reviews for CR-GGN-2010-7877 4

EN-DC-115 Engineering Change Process 11

DRAWINGS

NUMBER TITLE REVISION

M-1127A Piping and Instrumentation Diagram Noblechem Monitoring 0

System

M-1081B Control Rod Drive Hydraulic System 28

M-1078A Reactor Recirculation System Unit 1 33

M-1079 Reactor Water Clean-up System Unit 1 46

M-1069A Process Sampling System Unit 1 24

OTHER

NUMBER TITLE DATE

Root Cause Evaluation Report-Control Room Air Conditioner October 16,

B Trip (Event Date 10-14-2010) 2010

GNRO- LER 2010-002-00Control Room Air Conditioning December

2010/00077 13, 2010

Root Cause Evaluation Report Mitigation Monitor Durability November 8,

Monitor Pump Failure 2010

MMS Skid Piping/Component Design Basis

Compliance with NRC Regulatory Guide 1.26

CONDITION REPORT

CR-GGN-2010-07315 CR-GGN-2010-08580 CR-GGN-2010-07852

ENGINEERING CHANGE

A-20 Attachment

EC13135 EC13132 EC13138

Section 4OA5 Temporary Instruction 2515/179

PROCEDURES

NUMBER TITLE REVISION

EN-RP-143 Source Control 7

MISCELLANEOUS DOCUMENTS

TITLE DATE

National Source Tracking System Annual Inventory Reconciliation Report 2010

National Source Tracking System Annual Inventory Reconciliation Report 2011

Section 4OA7: Licensee-Identified Violations

CONDITION REPORT

CR-GGN-2011-00851

A-21 Attachment